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    <title>2026 (4) TMI 1174 - ITAT DEHRADUN</title>
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    <description>Disallowance under section 40(a)(ia) could not survive where the assessee produced the ledger, TDS return and Form 26AS showing deduction and deposit of tax on the payment, as those documents established compliance and removed the basis for disallowance. Addition of apple-sale agricultural income as unexplained income under section 69A was also unsustainable because ownership of 7,500 apple trees was supported by the will and land records, the Revenue did not dispute that ownership, and the declared income matched earlier accepted years; in the absence of contrary corroborative material, the receipts could not be treated as unexplained. Both additions were deleted.</description>
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    <pubDate>Wed, 25 Mar 2026 00:00:00 +0530</pubDate>
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      <title>2026 (4) TMI 1174 - ITAT DEHRADUN</title>
      <link>https://www.taxtmi.com/caselaws?id=790105</link>
      <description>Disallowance under section 40(a)(ia) could not survive where the assessee produced the ledger, TDS return and Form 26AS showing deduction and deposit of tax on the payment, as those documents established compliance and removed the basis for disallowance. Addition of apple-sale agricultural income as unexplained income under section 69A was also unsustainable because ownership of 7,500 apple trees was supported by the will and land records, the Revenue did not dispute that ownership, and the declared income matched earlier accepted years; in the absence of contrary corroborative material, the receipts could not be treated as unexplained. Both additions were deleted.</description>
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