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    <title>2025 (8) TMI 1672 - ITAT AHMEDABAD</title>
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    <description>Notional interest on loans and advances could not be added where the record did not show that borrowed funds were used for those advances and no interest expenditure had been disallowed; the estimate was unsupported by evidence, so the addition was deleted. An enhancement based only on a disclosure before the Settlement Commission could not be sustained where no notice under section 251(2) was issued and no reasonable opportunity of hearing was given; the disclosure alone was insufficient in assessment proceedings, so the enhancement and consequential addition were set aside.</description>
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