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    <title>2026 (6) TMI 678 - ITAT BANGALORE</title>
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    <description>ITAT Bangalore held that Form No. 10 filed for accumulation, by itself, did not justify treating Rs. 2 crores as undisclosed income absent evidence of actual unrecorded receipt, so the addition was deleted. It also held that opening capital work-in-progress reflected in the balance sheet could not be disallowed as application of income when it was not claimed as current year application, and that addition was therefore deleted. The decision further accepted, subject to verification, that excess application of earlier years could be set off against current year income. The operative principle was that additions require evidentiary support and that only amounts actually claimed as application can be scrutinised on that basis.</description>
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      <title>2026 (6) TMI 678 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=793297</link>
      <description>ITAT Bangalore held that Form No. 10 filed for accumulation, by itself, did not justify treating Rs. 2 crores as undisclosed income absent evidence of actual unrecorded receipt, so the addition was deleted. It also held that opening capital work-in-progress reflected in the balance sheet could not be disallowed as application of income when it was not claimed as current year application, and that addition was therefore deleted. The decision further accepted, subject to verification, that excess application of earlier years could be set off against current year income. The operative principle was that additions require evidentiary support and that only amounts actually claimed as application can be scrutinised on that basis.</description>
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