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    <title>2026 (4) TMI 1702 - ITAT NAGPUR</title>
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    <description>Cash deposits linked to declared trading turnover could not be taxed under section 68 as unexplained income where the Revenue failed to show a non-business source. The deposits were treated as business receipts circulating in the assessee&#039;s trading activity, and the absence of complete books could justify rejection of accounts and estimation of income, but not taxation of the entire gross receipts. Only the profit element embedded in such receipts can be brought to tax. The addition under section 68 was therefore deleted, and income was to be determined by applying a reasonable net profit rate on turnover after giving the assessee an opportunity to be heard.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790633</link>
      <description>Cash deposits linked to declared trading turnover could not be taxed under section 68 as unexplained income where the Revenue failed to show a non-business source. The deposits were treated as business receipts circulating in the assessee&#039;s trading activity, and the absence of complete books could justify rejection of accounts and estimation of income, but not taxation of the entire gross receipts. Only the profit element embedded in such receipts can be brought to tax. The addition under section 68 was therefore deleted, and income was to be determined by applying a reasonable net profit rate on turnover after giving the assessee an opportunity to be heard.</description>
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