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    <title>2026 (3) TMI 1398 - ITAT AHMEDABAD</title>
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    <description>Primary evidence of identity, genuineness and creditworthiness supported unsecured loans, and the Revenue did not rebut that evidence with independent inquiry or proof of a cash trail, so the section 68 addition was unsustainable. Seized Excel notings linked to recorded bank withdrawals and books were not shown to represent independent unexplained expenditure, so the section 69C addition failed. For disputed purchases, where sales, stock records and banking trail were accepted, only the profit element could be taxed, and the 6% estimate was upheld. The stock-difference addition was deleted because the lower book stock figure was supported and no clandestine trading was proved. One loose-material issue was remitted for factual verification.</description>
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      <link>https://www.taxtmi.com/caselaws?id=788643</link>
      <description>Primary evidence of identity, genuineness and creditworthiness supported unsecured loans, and the Revenue did not rebut that evidence with independent inquiry or proof of a cash trail, so the section 68 addition was unsustainable. Seized Excel notings linked to recorded bank withdrawals and books were not shown to represent independent unexplained expenditure, so the section 69C addition failed. For disputed purchases, where sales, stock records and banking trail were accepted, only the profit element could be taxed, and the 6% estimate was upheld. The stock-difference addition was deleted because the lower book stock figure was supported and no clandestine trading was proved. One loose-material issue was remitted for factual verification.</description>
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