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    <title>2026 (4) TMI 975 - ITAT RAJKOT</title>
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    <description>Where the Revenue has accepted the same land transaction in a co-owner&#039;s hands, it cannot make an addition for alleged on-money payment or unexplained investment against another similarly placed co-owner without any distinguishing material. The assessee was found to stand on the same footing as the co-owner, and the Revenue failed to show any basis for differential treatment. The addition was therefore deleted. As relief was granted on this substantive issue, the additional legal grounds were not examined and were treated as academic.</description>
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      <link>https://www.taxtmi.com/caselaws?id=789906</link>
      <description>Where the Revenue has accepted the same land transaction in a co-owner&#039;s hands, it cannot make an addition for alleged on-money payment or unexplained investment against another similarly placed co-owner without any distinguishing material. The assessee was found to stand on the same footing as the co-owner, and the Revenue failed to show any basis for differential treatment. The addition was therefore deleted. As relief was granted on this substantive issue, the additional legal grounds were not examined and were treated as academic.</description>
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