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    <title>2026 (5) TMI 951 - ITAT AGRA</title>
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    <description>Tax additions and disallowances were examined on multiple principles: unexplained advances for land were restricted by the peak balance accepted in earlier years, and cash advances for land were held outside section 40A(3) because they were not expenditure payments in the statutory sense. Disallowance under section 40(a)(ia) was deleted where the recipient had already accounted for the income and paid tax, while interest under section 36(1)(iii) was disallowed only for advances lacking business nexus. Job-work receipts were taxed only to the extent of the embedded profit element, not on gross receipts. The work-in-progress addition based on survey surrender and valuation defects was sustained where the books treatment was found unsupported.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791749</link>
      <description>Tax additions and disallowances were examined on multiple principles: unexplained advances for land were restricted by the peak balance accepted in earlier years, and cash advances for land were held outside section 40A(3) because they were not expenditure payments in the statutory sense. Disallowance under section 40(a)(ia) was deleted where the recipient had already accounted for the income and paid tax, while interest under section 36(1)(iii) was disallowed only for advances lacking business nexus. Job-work receipts were taxed only to the extent of the embedded profit element, not on gross receipts. The work-in-progress addition based on survey surrender and valuation defects was sustained where the books treatment was found unsupported.</description>
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