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    <title>2026 (4) TMI 410 - ITAT SURAT</title>
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    <description>Cash deposits made during the demonetisation period were held to be unexplained because the assessee failed to substantiate the claim that the funds came from earlier withdrawals meant for an immovable property transaction. The explanation was rejected for want of documentary support, including any agreement to sell, advance receipt, sale deed, or proof of related payments. Applying sections 68 and 69A, the burden to prove the nature and source of the cash remained on the assessee, and a mere oral explanation was found insufficient. The surrounding circumstances, including repeated borrowings, multiple withdrawals, long retention of cash, and redeposit of the same amount, were treated as inconsistent with normal commercial conduct and human probabilities, so the addition was sustained.</description>
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    <pubDate>Thu, 26 Mar 2026 00:00:00 +0530</pubDate>
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      <title>2026 (4) TMI 410 - ITAT SURAT</title>
      <link>https://www.taxtmi.com/caselaws?id=789341</link>
      <description>Cash deposits made during the demonetisation period were held to be unexplained because the assessee failed to substantiate the claim that the funds came from earlier withdrawals meant for an immovable property transaction. The explanation was rejected for want of documentary support, including any agreement to sell, advance receipt, sale deed, or proof of related payments. Applying sections 68 and 69A, the burden to prove the nature and source of the cash remained on the assessee, and a mere oral explanation was found insufficient. The surrounding circumstances, including repeated borrowings, multiple withdrawals, long retention of cash, and redeposit of the same amount, were treated as inconsistent with normal commercial conduct and human probabilities, so the addition was sustained.</description>
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      <pubDate>Thu, 26 Mar 2026 00:00:00 +0530</pubDate>
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