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    <title>2026 (3) TMI 732 - ITAT RAJKOT</title>
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    <description>Validity of reassessment under section 147/notice under section 148 was upheld on the basis of seized material, digital data, third party statements and authorised approval, so reopening stands. Where undisclosed &#039;on money&#039; is proved, only the profit element is taxable and must be estimated on factual comparables; Tribunal fixed the estimate at 10% and directed recomputation. ICDS III was held inapplicable to the contractee and unaccounted profit is taxable in the year of sale deed execution. Telescoping was allowed by setting off confirmed unaccounted profit against alleged cash loans, and revenue appeals were dismissed accordingly.</description>
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    <pubDate>Tue, 24 Feb 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=787977</link>
      <description>Validity of reassessment under section 147/notice under section 148 was upheld on the basis of seized material, digital data, third party statements and authorised approval, so reopening stands. Where undisclosed &#039;on money&#039; is proved, only the profit element is taxable and must be estimated on factual comparables; Tribunal fixed the estimate at 10% and directed recomputation. ICDS III was held inapplicable to the contractee and unaccounted profit is taxable in the year of sale deed execution. Telescoping was allowed by setting off confirmed unaccounted profit against alleged cash loans, and revenue appeals were dismissed accordingly.</description>
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