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    <title>2026 (6) TMI 1124 - ITAT AHMEDABAD</title>
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    <description>Additions in search-related proceedings must rest on reliable evidence, and for completed assessments under section 153A they require incriminating material specific to the relevant year; extrapolation alone is insufficient. On the stock-difference issue, an estimated physical verification without scientific working and against a supported reconciliation could not sustain the addition, so it was deleted. For alleged unaccounted production, WhatsApp chats and search statements justified only a restricted profit addition for a limited period, which was sustained. The section 41(1) liability addition failed because mere outstanding creditors do not establish cessation absent evidence of remission. Additions under sections 68 and 69 were also deleted for lack of corroborative evidence.</description>
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      <description>Additions in search-related proceedings must rest on reliable evidence, and for completed assessments under section 153A they require incriminating material specific to the relevant year; extrapolation alone is insufficient. On the stock-difference issue, an estimated physical verification without scientific working and against a supported reconciliation could not sustain the addition, so it was deleted. For alleged unaccounted production, WhatsApp chats and search statements justified only a restricted profit addition for a limited period, which was sustained. The section 41(1) liability addition failed because mere outstanding creditors do not establish cessation absent evidence of remission. Additions under sections 68 and 69 were also deleted for lack of corroborative evidence.</description>
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