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    <title>2025 (12) TMI 1709 - ITAT KOLKATA</title>
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    <description>Additions treating fixed assets as unexplained investment under s.69 were unsustainable because the asset value was consistently reflected in the balance sheets across years and had been disclosed in the belated return; the nil disclosure in the reassessment return was a clerical error and the AO produced no material to show investment during the relevant FY, so the addition was deleted. Rejection of closing cash balance and consequential denial of capitalisation were unjustified since cash-in-hand was supported by the balance sheet and GST returns; enhancement of closing capital was allowed. Addition under s.69A for cash was quashed and deleted because documentary evidence for cash sales and cash balance was not faulted and the AO violated statutory procedure by not issuing a show-cause notice before completing assessment. Penalties under s.272A(1)(d) were deleted as the quantum additions did not survive.</description>
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    <pubDate>Mon, 08 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1709 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=784169</link>
      <description>Additions treating fixed assets as unexplained investment under s.69 were unsustainable because the asset value was consistently reflected in the balance sheets across years and had been disclosed in the belated return; the nil disclosure in the reassessment return was a clerical error and the AO produced no material to show investment during the relevant FY, so the addition was deleted. Rejection of closing cash balance and consequential denial of capitalisation were unjustified since cash-in-hand was supported by the balance sheet and GST returns; enhancement of closing capital was allowed. Addition under s.69A for cash was quashed and deleted because documentary evidence for cash sales and cash balance was not faulted and the AO violated statutory procedure by not issuing a show-cause notice before completing assessment. Penalties under s.272A(1)(d) were deleted as the quantum additions did not survive.</description>
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      <pubDate>Mon, 08 Dec 2025 00:00:00 +0530</pubDate>
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