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    <title>2025 (12) TMI 1219 - ITAT RAJKOT</title>
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    <description>The dominant issue was whether cash deposits/withdrawals and time deposits could be treated as unexplained money under s.69A on the basis that two partnership firms with identical partners and profit-sharing were effectively one assessee due to year-end consolidation. The ITAT held that each firm remains a distinct unit of assessment under s.2(31) and maintained separate audited books; preparing a consolidated profit and loss account and transferring year-end entries for administrative convenience, while offering tax on the consolidated profit at the same applicable rate, did not evidence escapement of income or tax evasion. Consequently, the s.69A addition premise failed and the revenue&#039;s appeal was dismissed.</description>
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    <pubDate>Mon, 15 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1219 - ITAT RAJKOT</title>
      <link>https://www.taxtmi.com/caselaws?id=783679</link>
      <description>The dominant issue was whether cash deposits/withdrawals and time deposits could be treated as unexplained money under s.69A on the basis that two partnership firms with identical partners and profit-sharing were effectively one assessee due to year-end consolidation. The ITAT held that each firm remains a distinct unit of assessment under s.2(31) and maintained separate audited books; preparing a consolidated profit and loss account and transferring year-end entries for administrative convenience, while offering tax on the consolidated profit at the same applicable rate, did not evidence escapement of income or tax evasion. Consequently, the s.69A addition premise failed and the revenue&#039;s appeal was dismissed.</description>
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      <pubDate>Mon, 15 Dec 2025 00:00:00 +0530</pubDate>
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