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    <title>2026 (5) TMI 1258 - ITAT NAGPUR</title>
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    <description>Unrecorded cash sales detected from seized loose papers were held not to justify sustaining the full addition under section 69A, because where sales outside the books are accepted, the related purchases and business outgoings cannot be ignored and only the profit element embedded in those sales is taxable. The Tribunal applied the rule of consistency and judicial discipline, noting that on substantially identical facts in earlier years the coordinate bench had already restricted the addition to profit. As no distinguishing material was shown for the year under appeal, the CIT(A)&#039;s restriction of the addition to the average gross profit rate on the unrecorded sales was upheld in favour of the assessee.</description>
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      <description>Unrecorded cash sales detected from seized loose papers were held not to justify sustaining the full addition under section 69A, because where sales outside the books are accepted, the related purchases and business outgoings cannot be ignored and only the profit element embedded in those sales is taxable. The Tribunal applied the rule of consistency and judicial discipline, noting that on substantially identical facts in earlier years the coordinate bench had already restricted the addition to profit. As no distinguishing material was shown for the year under appeal, the CIT(A)&#039;s restriction of the addition to the average gross profit rate on the unrecorded sales was upheld in favour of the assessee.</description>
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