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    <title>2025 (7) TMI 1750 - ITAT RAIPUR</title>
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    <description>The ITAT Raipur condoned a 743-day delay in filing the appeal, finding no deliberate or malafide conduct by the assessee and no evidence from the department to the contrary. The tribunal held that the delay was due to circumstances beyond the assessee&#039;s control. Regarding the addition under sections 68 or 69A for unexplained cash credits, the ITAT found the application of an incorrect charging section by the AO demonstrated non-application of mind and vitiated the assessment and appellate orders. Following precedent, the tribunal ruled that additions based on incorrect provisions are unsustainable. The AO was directed to delete the entire addition, and the assessee&#039;s appeal was allowed.</description>
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      <title>2025 (7) TMI 1750 - ITAT RAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=775682</link>
      <description>The ITAT Raipur condoned a 743-day delay in filing the appeal, finding no deliberate or malafide conduct by the assessee and no evidence from the department to the contrary. The tribunal held that the delay was due to circumstances beyond the assessee&#039;s control. Regarding the addition under sections 68 or 69A for unexplained cash credits, the ITAT found the application of an incorrect charging section by the AO demonstrated non-application of mind and vitiated the assessment and appellate orders. Following precedent, the tribunal ruled that additions based on incorrect provisions are unsustainable. The AO was directed to delete the entire addition, and the assessee&#039;s appeal was allowed.</description>
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