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    <title>2026 (5) TMI 397 - ITAT DELHI</title>
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    <description>In an unabated assessment year under section 153A, additions cannot be sustained without incriminating material, and the article notes that an alleged gift addition failed on that basis. On unexplained jewellery, the seized material and surrounding facts supported only a restricted addition, as the explanation was partly accepted but not in full. For alleged unexplained expenditure, rough notings by themselves were insufficient where they were unsupported by corroborative evidence and the assessee&#039;s explanation was backed by a statement recorded during search. The overall result was mixed, with full relief on one issue, a limited addition on jewellery, and deletion sustained on the expenditure issue.</description>
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      <title>2026 (5) TMI 397 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=791195</link>
      <description>In an unabated assessment year under section 153A, additions cannot be sustained without incriminating material, and the article notes that an alleged gift addition failed on that basis. On unexplained jewellery, the seized material and surrounding facts supported only a restricted addition, as the explanation was partly accepted but not in full. For alleged unexplained expenditure, rough notings by themselves were insufficient where they were unsupported by corroborative evidence and the assessee&#039;s explanation was backed by a statement recorded during search. The overall result was mixed, with full relief on one issue, a limited addition on jewellery, and deletion sustained on the expenditure issue.</description>
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