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    <title>2025 (7) TMI 101 - ITAT HYDERABAD</title>
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    <description>Additions treating bank-received advances/creditors as unaccounted land-sale consideration were held unsustainable where the AO failed to link receipts to any specific sale, title transfer, or &quot;on-money&quot; material, and merely doubted the nomenclature in books; at most, s.68 could apply only to sums received in the relevant year if cash-credit conditions were met, hence the additions were deleted. Additions under s.68 for customer advances were unjustified when ledgers, bank statements, and subsequent registered sale deeds showed adjustment against sale consideration, and non-furnishing of a few confirmations was for bona fide impossibility; the additions were deleted. For unreported plot sales, only the profit element was assessable since cost remained in closing stock and documentary sale deeds prevailed over an erroneous statement; the relief was upheld. Disallowance u/s 40(a)(ia) was rightly deleted as the recipient had offered the income to tax under the second proviso. A surrender based solely on a search statement without incriminating material was deleted.</description>
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    <pubDate>Thu, 15 May 2025 00:00:00 +0530</pubDate>
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      <title>2025 (7) TMI 101 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=774033</link>
      <description>Additions treating bank-received advances/creditors as unaccounted land-sale consideration were held unsustainable where the AO failed to link receipts to any specific sale, title transfer, or &quot;on-money&quot; material, and merely doubted the nomenclature in books; at most, s.68 could apply only to sums received in the relevant year if cash-credit conditions were met, hence the additions were deleted. Additions under s.68 for customer advances were unjustified when ledgers, bank statements, and subsequent registered sale deeds showed adjustment against sale consideration, and non-furnishing of a few confirmations was for bona fide impossibility; the additions were deleted. For unreported plot sales, only the profit element was assessable since cost remained in closing stock and documentary sale deeds prevailed over an erroneous statement; the relief was upheld. Disallowance u/s 40(a)(ia) was rightly deleted as the recipient had offered the income to tax under the second proviso. A surrender based solely on a search statement without incriminating material was deleted.</description>
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      <pubDate>Thu, 15 May 2025 00:00:00 +0530</pubDate>
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