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    <title>2026 (6) TMI 237 - ITAT SURAT</title>
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    <description>Investments in mutual funds and insurance policies were examined under section 69, with the related question whether section 115BBE should apply. The assessee produced balance sheet, capital account, investment statements, land records and crop-sale evidence to explain the source of funds, but part of the material was considered self-supporting and not fully reliable. The explanation was therefore not accepted in full, yet the receipts were not to be taxed in gross. The addition was restricted on an estimated basis by applying a 5% net profit rate to the disputed amount, and the resulting addition was directed to be made under the normal tax provisions rather than section 115BBE.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792856</link>
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