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    <title>2026 (4) TMI 1464 - ITAT DEHRADUN</title>
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    <description>Alleged bogus purchases were sent back for fresh verification because the record lacked an effective remand report and the genuineness of the purchases had not been fully tested. The disallowance under section 40(a)(ia) was deleted because the net purchases, after excluding GST, fell below the threshold relevant to section 194Q, so the statutory condition for disallowance was not met. Surrendered excess stock was held to retain the character of business income, as it arose from regular business activity and no separate source was shown; it was therefore not assessable as unexplained money under section 69A or taxed at the special rate under section 115BBE.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790395</link>
      <description>Alleged bogus purchases were sent back for fresh verification because the record lacked an effective remand report and the genuineness of the purchases had not been fully tested. The disallowance under section 40(a)(ia) was deleted because the net purchases, after excluding GST, fell below the threshold relevant to section 194Q, so the statutory condition for disallowance was not met. Surrendered excess stock was held to retain the character of business income, as it arose from regular business activity and no separate source was shown; it was therefore not assessable as unexplained money under section 69A or taxed at the special rate under section 115BBE.</description>
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