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    <title>2025 (12) TMI 1165 - ITAT MUMBAI</title>
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    <description>The dominant issue was whether advances received and cash withdrawals could be added as unexplained money under s.69A. The ITAT held that s.69A requires establishing that the assessee was the owner of unexplained money and cannot rest on suspicion, while incomplete substantiation of expenditure (including absence of primary vouchers) may justify only a reasonable estimate rather than treating the entire amount as unexplained. As the AO had not examined foundational facts such as TDS reversal, treatment of advances in the employer&#039;s books, the complete s.133(6) response, and utilization of withdrawals, the assessment was held unsustainable and the matter was remanded to the AO for limited verification with directions, including estimation-based disallowance where vouchers are lacking.</description>
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    <pubDate>Wed, 10 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1165 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=783625</link>
      <description>The dominant issue was whether advances received and cash withdrawals could be added as unexplained money under s.69A. The ITAT held that s.69A requires establishing that the assessee was the owner of unexplained money and cannot rest on suspicion, while incomplete substantiation of expenditure (including absence of primary vouchers) may justify only a reasonable estimate rather than treating the entire amount as unexplained. As the AO had not examined foundational facts such as TDS reversal, treatment of advances in the employer&#039;s books, the complete s.133(6) response, and utilization of withdrawals, the assessment was held unsustainable and the matter was remanded to the AO for limited verification with directions, including estimation-based disallowance where vouchers are lacking.</description>
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      <pubDate>Wed, 10 Dec 2025 00:00:00 +0530</pubDate>
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