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    <title>2025 (12) TMI 1108 - ITAT MUMBAI</title>
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    <description>Whether an ad hoc addition by estimating closing work-in-progress at 1% was sustainable without rejecting the books of account was the dominant issue. The Tribunal held that the taxpayer had substantiated the closing work-in-progress through complete particulars, including running bills prepared by competent departments and received in the subsequent quarter, and bank statements evidencing receipt of payments relating to purchases reflected in such work-in-progress. Since the AO neither rejected the books under the applicable law nor demonstrated any defect warranting estimation, the 1% valuation was held to be arbitrary, devoid of rational basis, and legally unsustainable. The addition was deleted and the appeal was allowed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=783568</link>
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