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    <title>2025 (2) TMI 1438 - ITAT DELHI</title>
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    <description>Unexplained cash payments for a student&#039;s fees were challenged as regular course fee and alleged capitation fee. The regular fee was substantiated by evidence of source and an affidavit confirming payment, so no addition was made. The capitation fee addition rested solely on a third party&#039;s statement which was not furnished to or confronted with the taxpayer; in the absence of material supporting that claim, the addition was held unsustainable and deleted. The taxpayer&#039;s appeal against both additions was allowed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=466509</link>
      <description>Unexplained cash payments for a student&#039;s fees were challenged as regular course fee and alleged capitation fee. The regular fee was substantiated by evidence of source and an affidavit confirming payment, so no addition was made. The capitation fee addition rested solely on a third party&#039;s statement which was not furnished to or confronted with the taxpayer; in the absence of material supporting that claim, the addition was held unsustainable and deleted. The taxpayer&#039;s appeal against both additions was allowed.</description>
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