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    <title>2025 (2) TMI 1858 - ITAT NAGPUR</title>
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    <description>Section 69C could not be applied to opening balances of sundry creditors because the amount represented a brought-forward liability from earlier years, not expenditure incurred in the relevant year; the addition was therefore unsustainable and deleted. Section 69C also did not support the addition for labour contractor expenses where the assessee produced bills, ledger accounts, TDS particulars and banking records, and the record contained no defect or corroborative evidence showing the payments were bogus; suspicion and third-party statements alone were insufficient, so the addition was deleted. The Revenue&#039;s challenge to both additions failed.</description>
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      <title>2025 (2) TMI 1858 - ITAT NAGPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=468671</link>
      <description>Section 69C could not be applied to opening balances of sundry creditors because the amount represented a brought-forward liability from earlier years, not expenditure incurred in the relevant year; the addition was therefore unsustainable and deleted. Section 69C also did not support the addition for labour contractor expenses where the assessee produced bills, ledger accounts, TDS particulars and banking records, and the record contained no defect or corroborative evidence showing the payments were bogus; suspicion and third-party statements alone were insufficient, so the addition was deleted. The Revenue&#039;s challenge to both additions failed.</description>
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      <pubDate>Fri, 14 Feb 2025 00:00:00 +0530</pubDate>
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