https://www.taxtmi.com/caselaws?id=784150 Whether cash entries in seized records could be treated as unexplained cash credits u/s 68 was determined by construing the diary as a whole: where cash and cheque transactions bore the same common code and cheque issuers were identified, the cash entries had to be presumed to pertain to those persons, not the assessee; the AO was directed to reduce the addition by the amount relatable to such common-code entries. For the remaining fund-flow entries, peak theory was held inapplicable because inflows and outflows were largely with different coded persons; only net inflows could be assessed, with set-off allowed for matching inflow/outflow under one code, resulting in sustenance of addition only to the reduced figure. Duplicate entries deleted by CIT(A) were upheld. Commission was directed to be computed at 1% on the recomputed transaction value. en-us Fri, 24 Oct 2025 00:00:00 +0530 Sat, 27 Dec 2025 13:05:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784150 Whether cash entries in seized records could be treated as unexplained cash credits u/s 68 was determined by construing the diary as a whole: where cash and cheque transactions bore the same common code and cheque issuers were identified, the cash entries had to be presumed to pertain to those persons, not the assessee; the AO was directed to reduce the addition by the amount relatable to such common-code entries. For the remaining fund-flow entries, peak theory was held inapplicable because inflows and outflows were largely with different coded persons; only net inflows could be assessed, with set-off allowed for matching inflow/outflow under one code, resulting in sustenance of addition only to the reduced figure. Duplicate entries deleted by CIT(A) were upheld. Commission was directed to be computed at 1% on the recomputed transaction value. Case-Laws Income Tax Fri, 24 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784150