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    <title>2026 (4) TMI 1532 - ITAT MUMBAI</title>
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    <description>Additional evidence going to the root of the dispute warranted remand where the nature of a payment under section 2(22)(e) depended on whether it was a commercial advance linked to business exigency, and where cash deposits under section 68 required factual verification of claimed sale proceeds and marriage gifts. The Tribunal also directed fresh examination of the disallowance under section 57 because the nexus between the claimed expenditure and income from other sources had not been properly tested. The assessment on the disputed issues was set aside for de novo adjudication after admission and verification of the additional material and due opportunity to the assessee.</description>
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      <description>Additional evidence going to the root of the dispute warranted remand where the nature of a payment under section 2(22)(e) depended on whether it was a commercial advance linked to business exigency, and where cash deposits under section 68 required factual verification of claimed sale proceeds and marriage gifts. The Tribunal also directed fresh examination of the disallowance under section 57 because the nexus between the claimed expenditure and income from other sources had not been properly tested. The assessment on the disputed issues was set aside for de novo adjudication after admission and verification of the additional material and due opportunity to the assessee.</description>
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