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    <title>2025 (9) TMI 845 - ITAT BANGALORE</title>
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    <description>Uncorroborated loose sheets, contradictory statements and the absence of cash seizure, bank trail or other independent evidence were insufficient to sustain additions for alleged capitation fee; the presumption under section 292C was rebutted and the addition was deleted. On that basis, denial of exemption under section 11 also failed, as the foundation for alleging violation of section 13(1)(c) did not survive and registration under section 12AA had been restored. For completed assessments under section 153A, additions could not be made for earlier years without incriminating material relatable to those specific years; extrapolation was impermissible. Donation disallowance was also deleted as application of income once exemption was accepted.</description>
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    <pubDate>Mon, 08 Sep 2025 00:00:00 +0530</pubDate>
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      <title>2025 (9) TMI 845 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=778356</link>
      <description>Uncorroborated loose sheets, contradictory statements and the absence of cash seizure, bank trail or other independent evidence were insufficient to sustain additions for alleged capitation fee; the presumption under section 292C was rebutted and the addition was deleted. On that basis, denial of exemption under section 11 also failed, as the foundation for alleging violation of section 13(1)(c) did not survive and registration under section 12AA had been restored. For completed assessments under section 153A, additions could not be made for earlier years without incriminating material relatable to those specific years; extrapolation was impermissible. Donation disallowance was also deleted as application of income once exemption was accepted.</description>
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