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    <title>2025 (3) TMI 1664 - ITAT MUMBAI</title>
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    <description>In search assessments involving unaccounted on-money receipts, only the profit element embedded in such receipts can be taxed, and the estimate must be based on material on record and a fair factual working. The record showed both on-money receipts and cash expenditure for the project, so taxing the entire gross receipts without deduction for expenditure was not justified. The first appellate estimate was found unsupported by a proper basis and inconsistent with the assessee&#039;s project-wise accounting pattern and profit history. On these facts, net profit was directed to be estimated at 22% instead of 26%, with corresponding relief to the assessee.</description>
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      <title>2025 (3) TMI 1664 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=468879</link>
      <description>In search assessments involving unaccounted on-money receipts, only the profit element embedded in such receipts can be taxed, and the estimate must be based on material on record and a fair factual working. The record showed both on-money receipts and cash expenditure for the project, so taxing the entire gross receipts without deduction for expenditure was not justified. The first appellate estimate was found unsupported by a proper basis and inconsistent with the assessee&#039;s project-wise accounting pattern and profit history. On these facts, net profit was directed to be estimated at 22% instead of 26%, with corresponding relief to the assessee.</description>
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