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    <title>2025 (1) TMI 1806 - ITAT DELHI</title>
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    <description>Cash deposits were accepted as made, but the source was not satisfactorily explained, so the unexplained amount under section 69A was estimated on a reasonable basis rather than sustained in full. The analysis also notes that section 115BBE was treated as applicable only to transactions on or after 01.04.2017. On penalty, non-appearance and alleged non-cooperation under section 272A(1)(d) were viewed in light of the Covid-19 period, which was treated as a justifiable cause. The result was partial relief on the quantum addition and deletion of the penalty, reflecting a mixed outcome overall.</description>
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      <description>Cash deposits were accepted as made, but the source was not satisfactorily explained, so the unexplained amount under section 69A was estimated on a reasonable basis rather than sustained in full. The analysis also notes that section 115BBE was treated as applicable only to transactions on or after 01.04.2017. On penalty, non-appearance and alleged non-cooperation under section 272A(1)(d) were viewed in light of the Covid-19 period, which was treated as a justifiable cause. The result was partial relief on the quantum addition and deletion of the penalty, reflecting a mixed outcome overall.</description>
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