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    <title>2026 (1) TMI 1470 - ITAT AHMEDABAD</title>
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    <description>Validity of reopening was decided on limitation grounds: notice for reopening was timebarred, so the reassessment was quashed and the impugned assessment annulled. On unaccounted onmoney receipts, the profit element was estimated by appellate authority at 17% of receipts and the benefit of telescoping declared income under IDS2016 was allowed, reducing taxable addition. For unsecured loans and related interest, the assessee proved identity, creditworthiness and repayment transactions; sourceofsource proof was not required and no cashcredit addition was made. Revenue appeals were dismissed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=785714</link>
      <description>Validity of reopening was decided on limitation grounds: notice for reopening was timebarred, so the reassessment was quashed and the impugned assessment annulled. On unaccounted onmoney receipts, the profit element was estimated by appellate authority at 17% of receipts and the benefit of telescoping declared income under IDS2016 was allowed, reducing taxable addition. For unsecured loans and related interest, the assessee proved identity, creditworthiness and repayment transactions; sourceofsource proof was not required and no cashcredit addition was made. Revenue appeals were dismissed.</description>
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