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    <title>2025 (8) TMI 1753 - ITAT CHENNAI</title>
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    <description>Notings/jottings in diaries/loose sheets seized from a third party during search, and adverse third-party statements, were held insufficient to sustain additions alleging cash returned against rebates in construction bills, since the material was inadmissible/vague, lacked linkage and independent corroboration, contained factual inconsistencies, and reliance on statements was vitiated by hearsay, contradictions, retraction, and denial of cross-examination; the additions for the relevant AYs were deleted and Revenue&#039;s appeal was dismissed. Addition for surplus from extra fees collected above the Government-prescribed fee was held unjustified because the receipts were applied to charitable objects and no s.13 violation was shown; exemption under s.11 was allowed and the addition was deleted. Surplus from incidental activities (hostel, transport, stationery) was treated as eligible for s.11 exemption; the addition was deleted.</description>
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    <pubDate>Thu, 14 Aug 2025 00:00:00 +0530</pubDate>
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      <title>2025 (8) TMI 1753 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=465551</link>
      <description>Notings/jottings in diaries/loose sheets seized from a third party during search, and adverse third-party statements, were held insufficient to sustain additions alleging cash returned against rebates in construction bills, since the material was inadmissible/vague, lacked linkage and independent corroboration, contained factual inconsistencies, and reliance on statements was vitiated by hearsay, contradictions, retraction, and denial of cross-examination; the additions for the relevant AYs were deleted and Revenue&#039;s appeal was dismissed. Addition for surplus from extra fees collected above the Government-prescribed fee was held unjustified because the receipts were applied to charitable objects and no s.13 violation was shown; exemption under s.11 was allowed and the addition was deleted. Surplus from incidental activities (hostel, transport, stationery) was treated as eligible for s.11 exemption; the addition was deleted.</description>
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