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    <title>2026 (2) TMI 1240 - ITAT DELHI</title>
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    <description>Where seized documents are attributable to the taxpayer under the statutory presumption, their contents may be used to quantify unaccounted business income and that quantified income may be set off against cash seized by applying the telescoping principle to avoid double taxation of income and its application; applying an industry commission rate to transactional entries was accepted as a reasonable method to quantify unaccounted income, resulting in certain additions being sustained while explained amounts and permitted allowances reduced other cash-based additions, and the Revenue appeal against these adjustments was dismissed.</description>
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      <description>Where seized documents are attributable to the taxpayer under the statutory presumption, their contents may be used to quantify unaccounted business income and that quantified income may be set off against cash seized by applying the telescoping principle to avoid double taxation of income and its application; applying an industry commission rate to transactional entries was accepted as a reasonable method to quantify unaccounted income, resulting in certain additions being sustained while explained amounts and permitted allowances reduced other cash-based additions, and the Revenue appeal against these adjustments was dismissed.</description>
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