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    <title>2026 (3) TMI 1604 - ITAT MUMBAI</title>
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    <description>Consultancy receipts supported by memoranda of understanding and banking evidence were held not to be fully assessable as unexplained income under section 69, because the transaction and receipt of income had prima facie credibility. At the same time, expenditure supported only by self-made vouchers and material first sought to be filed at the appellate stage remained insufficiently proved, and additional evidence was not admitted without satisfying Rule 46A. The disallowance was therefore confined to a reasonable amount for unverifiable expenses, with the balance deleted.</description>
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      <description>Consultancy receipts supported by memoranda of understanding and banking evidence were held not to be fully assessable as unexplained income under section 69, because the transaction and receipt of income had prima facie credibility. At the same time, expenditure supported only by self-made vouchers and material first sought to be filed at the appellate stage remained insufficiently proved, and additional evidence was not admitted without satisfying Rule 46A. The disallowance was therefore confined to a reasonable amount for unverifiable expenses, with the balance deleted.</description>
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