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    <title>2026 (1) TMI 293 - ITAT PUNE</title>
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    <description>Additional income disclosed during search and offered as business income from the sole activity of land trading could not be assessed as unexplained cash credit under s.68 r.w.s. 115BBE, since no independent undisclosed activity was found and the business treatment was accepted; the statement under s.132(4) had to be read as a whole, precluding selective reliance by Revenue; the s.68/115BBE addition was deleted. Enhancement of capital gains based on an unsigned, undated seized sheet and an uncorroborated third-party statement, without concrete evidence of on-money, was unsustainable; the addition was deleted. Directions permitting telescoping/set-off of disclosed cash against other additions were upheld. Deletion of s.69C addition was affirmed for want of infirmity in the CIT(A)&#039;s verification. Addition under s.69 r.w.s. 115BBE based on a cancelled loose paper, absent corroboration, was set aside and deleted.</description>
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    <pubDate>Fri, 21 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 293 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=784537</link>
      <description>Additional income disclosed during search and offered as business income from the sole activity of land trading could not be assessed as unexplained cash credit under s.68 r.w.s. 115BBE, since no independent undisclosed activity was found and the business treatment was accepted; the statement under s.132(4) had to be read as a whole, precluding selective reliance by Revenue; the s.68/115BBE addition was deleted. Enhancement of capital gains based on an unsigned, undated seized sheet and an uncorroborated third-party statement, without concrete evidence of on-money, was unsustainable; the addition was deleted. Directions permitting telescoping/set-off of disclosed cash against other additions were upheld. Deletion of s.69C addition was affirmed for want of infirmity in the CIT(A)&#039;s verification. Addition under s.69 r.w.s. 115BBE based on a cancelled loose paper, absent corroboration, was set aside and deleted.</description>
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      <pubDate>Fri, 21 Nov 2025 00:00:00 +0530</pubDate>
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