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    <title>2026 (4) TMI 645 - ITAT SURAT</title>
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    <description>Where bank credits represent business receipts, only the profit element embedded in those receipts can be taxed, not the entire gross deposits; the addition was therefore restricted to 8% of the credits and the balance deleted. A claim that investment in immovable property was funded from business income and partnership withdrawals required factual verification, so the matter was remitted for limited examination of telescoping. Commercial properties used for business could not be subjected to notional rental income, so that addition was deleted. A separate addition for difference in receipts could not survive where the same bank deposits had already been estimated, as this would amount to double taxation; that addition was also deleted.</description>
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      <title>2026 (4) TMI 645 - ITAT SURAT</title>
      <link>https://www.taxtmi.com/caselaws?id=789576</link>
      <description>Where bank credits represent business receipts, only the profit element embedded in those receipts can be taxed, not the entire gross deposits; the addition was therefore restricted to 8% of the credits and the balance deleted. A claim that investment in immovable property was funded from business income and partnership withdrawals required factual verification, so the matter was remitted for limited examination of telescoping. Commercial properties used for business could not be subjected to notional rental income, so that addition was deleted. A separate addition for difference in receipts could not survive where the same bank deposits had already been estimated, as this would amount to double taxation; that addition was also deleted.</description>
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