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    <title>2024 (6) TMI 1538 - ITAT JABALPUR</title>
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    <description>WhatsApp chats relied on for s.69 unexplained investment were held to evidence only hawala cash transfers, entitling the assessee merely to commission income; as Revenue produced no contrary material, only commission at Rs.300 per lakh on the transferred sum was taxable, and the s.69 addition was restricted accordingly. For impounded material showing unaccounted purchases/sales, applying MP HC precedents, only the profit element in unaccounted sales was assessable; adopting the assessee&#039;s disclosed GP rate of 26.40%, the CIT(A)&#039;s profit addition was sustained. Reassessment was upheld since an admitted unaccounted purchase provided prima facie &quot;reason to believe&quot;; the challenge failed. Excess-stock addition was deleted as the survey statement contained no admission.</description>
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    <pubDate>Fri, 28 Jun 2024 00:00:00 +0530</pubDate>
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      <title>2024 (6) TMI 1538 - ITAT JABALPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=465805</link>
      <description>WhatsApp chats relied on for s.69 unexplained investment were held to evidence only hawala cash transfers, entitling the assessee merely to commission income; as Revenue produced no contrary material, only commission at Rs.300 per lakh on the transferred sum was taxable, and the s.69 addition was restricted accordingly. For impounded material showing unaccounted purchases/sales, applying MP HC precedents, only the profit element in unaccounted sales was assessable; adopting the assessee&#039;s disclosed GP rate of 26.40%, the CIT(A)&#039;s profit addition was sustained. Reassessment was upheld since an admitted unaccounted purchase provided prima facie &quot;reason to believe&quot;; the challenge failed. Excess-stock addition was deleted as the survey statement contained no admission.</description>
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