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    <title>2026 (6) TMI 365 - ITAT DELHI</title>
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    <description>Cash deposits and other credits were treated as only partly unexplained because the assessee&#039;s sales-based explanation was not fully dislodged, so the addition was restricted on estimation rather than sustained in full. The higher-rate tax regime under section 115BBE was held inapplicable to the relevant pre-01.04.2017 period, with normal tax provisions applying instead. Penalties under sections 270A, 271AAC(1) and 272A(1)(d) were deleted because the estimated addition did not establish concrete misreporting, the penalty linked to section 115BBE failed with that provision, and the first appeal was rejected on limitation without adequate opportunity.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792984</link>
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