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    <title>2025 (12) TMI 1211 - ITAT HYDERABAD</title>
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    <description>Additions based on cash receipts and entries in documents impounded during survey u/s 133A were disputed on the ground that the transactions belonged to a partnership firm, not the individual assessee. The ITAT held that the AO did not dispute the firm&#039;s ownership and sale of the underlying properties, and the impounded receipts/advances were recorded in the firm&#039;s books as &quot;advances for sale of flats&quot; and offered to tax in the firm&#039;s assessments; absent further evidence linking the receipts to the assessee&#039;s independent income, the additions were unsustainable. The CIT(A) erred in sustaining the additions without appreciating these facts, and the AO was directed to delete both additions.</description>
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    <pubDate>Wed, 10 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1211 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=783671</link>
      <description>Additions based on cash receipts and entries in documents impounded during survey u/s 133A were disputed on the ground that the transactions belonged to a partnership firm, not the individual assessee. The ITAT held that the AO did not dispute the firm&#039;s ownership and sale of the underlying properties, and the impounded receipts/advances were recorded in the firm&#039;s books as &quot;advances for sale of flats&quot; and offered to tax in the firm&#039;s assessments; absent further evidence linking the receipts to the assessee&#039;s independent income, the additions were unsustainable. The CIT(A) erred in sustaining the additions without appreciating these facts, and the AO was directed to delete both additions.</description>
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