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    <title>2024 (7) TMI 1787 - ITAT NAGPUR</title>
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    <description>Third-party documents and impounded material did not justify additions where the assessee&#039;s regular books already recorded the relevant commission income and the figures would have led to duplication. The commentary also states that unexplained expenditure under section 69C cannot be added unless it is shown that the assessee actually incurred the expenditure from its own funds; entries found at a third party&#039;s premises, without corroboration, were insufficient. On the facts described, the assessee was treated as a broker or marketing associate acting as a conduit, and the Revenue&#039;s appeal failed on both additions.</description>
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      <description>Third-party documents and impounded material did not justify additions where the assessee&#039;s regular books already recorded the relevant commission income and the figures would have led to duplication. The commentary also states that unexplained expenditure under section 69C cannot be added unless it is shown that the assessee actually incurred the expenditure from its own funds; entries found at a third party&#039;s premises, without corroboration, were insufficient. On the facts described, the assessee was treated as a broker or marketing associate acting as a conduit, and the Revenue&#039;s appeal failed on both additions.</description>
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