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    <title>2026 (3) TMI 1278 - ITAT MUMBAI</title>
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    <description>Section 44AD and section 44ADA operate in distinct, mutually exclusive fields: 44AD applies to eligible businesses on a presumptive basis, while 44ADA is confined to specified professions at 50%. The Assessing Officer applied a 50% rate by analogy to section 44ADA without establishing that the assessee was carrying on a notified profession or producing material to displace the declared presumptive income under section 44AD. As the turnover was accepted and no suppression of receipts or inflation of expenses was shown, the declared income under section 44AD was accepted and the substitution of the 50% rate was treated as legally unsustainable.</description>
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