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    <title>2026 (6) TMI 1078 - ITAT MUMBAI</title>
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    <description>A justice-oriented approach was applied to condone a 79-day delay in filing the first appeal, where the assessee showed bona fide cause, lack of independent income and dependence on tax consultants. On the merits, an addition as unexplained investment under section 69 was unsustainable because the assessee produced the sale deed, bank statements and payment trail showing direct remittance from the father&#039;s disclosed bank account to the seller. Once that primary onus was discharged, the burden shifted to the Revenue, which brought no adverse material; suspicion and the absence of a formal gift deed were insufficient to uphold the addition. The appeal was allowed and the addition was deleted.</description>
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      <title>2026 (6) TMI 1078 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=793697</link>
      <description>A justice-oriented approach was applied to condone a 79-day delay in filing the first appeal, where the assessee showed bona fide cause, lack of independent income and dependence on tax consultants. On the merits, an addition as unexplained investment under section 69 was unsustainable because the assessee produced the sale deed, bank statements and payment trail showing direct remittance from the father&#039;s disclosed bank account to the seller. Once that primary onus was discharged, the burden shifted to the Revenue, which brought no adverse material; suspicion and the absence of a formal gift deed were insufficient to uphold the addition. The appeal was allowed and the addition was deleted.</description>
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