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    <title>2026 (6) TMI 1176 - ITAT CHENNAI</title>
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    <description>Cash deposits in an agricultural overdraft account were not treated as wholly unexplained under section 69A because the account context supported an agricultural source, even though complete land, crop, sale and cultivation records were not produced. In the absence of adverse Revenue material showing any other undisclosed source, only 50% of the deposits was sustained as unexplained on a reasonable-estimation basis, with the balance accepted as explained. The sustained addition was also held not liable to the amended enhanced tax rate under section 115BBE for Assessment Year 2017-18, as that regime applies prospectively from 01.04.2017, and tax was confined to normal rates.</description>
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      <description>Cash deposits in an agricultural overdraft account were not treated as wholly unexplained under section 69A because the account context supported an agricultural source, even though complete land, crop, sale and cultivation records were not produced. In the absence of adverse Revenue material showing any other undisclosed source, only 50% of the deposits was sustained as unexplained on a reasonable-estimation basis, with the balance accepted as explained. The sustained addition was also held not liable to the amended enhanced tax rate under section 115BBE for Assessment Year 2017-18, as that regime applies prospectively from 01.04.2017, and tax was confined to normal rates.</description>
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