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    <title>2026 (6) TMI 1383 - ITAT AGRA</title>
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    <description>Additions treating M/s. Jain Bullion as the assessee&#039;s benami concern, including the section 68 cash-deposit addition and estimated gross profit addition, were deleted because the record showed an independent proprietary business, supported books, stock, cash flow, VAT returns and bank trail, with no specific defect in the audited accounts. The rejection of books and attribution of the concern to the assessee were not supported by concrete evidence. The notional annual letting value addition under section 23 was also deleted because no incriminating material was found in search and the addition was inconsistent with the treatment in other years. All disputed additions were set aside in favour of the assessee.</description>
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      <description>Additions treating M/s. Jain Bullion as the assessee&#039;s benami concern, including the section 68 cash-deposit addition and estimated gross profit addition, were deleted because the record showed an independent proprietary business, supported books, stock, cash flow, VAT returns and bank trail, with no specific defect in the audited accounts. The rejection of books and attribution of the concern to the assessee were not supported by concrete evidence. The notional annual letting value addition under section 23 was also deleted because no incriminating material was found in search and the addition was inconsistent with the treatment in other years. All disputed additions were set aside in favour of the assessee.</description>
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