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    <title>2025 (12) TMI 1426 - ITAT HYDERABAD</title>
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    <description>Whether addition could be sustained for difference between income admitted in search statement u/s 132(4) and income returned u/s 153C. The Tribunal held that the AO erroneously considered only income offered under &quot;discrepancies and errors in gross receipts/expenses&quot; and ignored income offered on an estimated basis from &quot;real estate business activity&quot;. On aggregating both heads, the additional income offered exceeded the amount admitted during search, thereby explaining the alleged shortfall. Consequently, the addition sustained by the AO/CIT(A) towards the difference was unsustainable, and the AO was directed to delete the addition of Rs. 8,82,278; the appeal was allowed.</description>
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    <pubDate>Fri, 28 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1426 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=783886</link>
      <description>Whether addition could be sustained for difference between income admitted in search statement u/s 132(4) and income returned u/s 153C. The Tribunal held that the AO erroneously considered only income offered under &quot;discrepancies and errors in gross receipts/expenses&quot; and ignored income offered on an estimated basis from &quot;real estate business activity&quot;. On aggregating both heads, the additional income offered exceeded the amount admitted during search, thereby explaining the alleged shortfall. Consequently, the addition sustained by the AO/CIT(A) towards the difference was unsustainable, and the AO was directed to delete the addition of Rs. 8,82,278; the appeal was allowed.</description>
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      <pubDate>Fri, 28 Nov 2025 00:00:00 +0530</pubDate>
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