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    <title>2026 (6) TMI 1455 - GUJARAT HIGH COURT</title>
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    <description>The HC held that the Tribunal&#039;s estimation of the income element in on-money receipts was a factual determination, not a substantial question of law under Section 260A of the Income-tax Act, 1961. The Tribunal had accepted receipt of on-money, rejected the Revenue&#039;s valuation basis from an email and agreement, and treated the assessee&#039;s admitted rate as a reasonable starting point. It further found that while the entire on-money could not be taxed as income, the absence of evidence of cash expenses outside the books justified a higher estimated percentage. As the findings were based on project accounts, turnover, profit ratio and the nature of the real estate business, no perversity was shown and the appeals failed.</description>
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      <description>The HC held that the Tribunal&#039;s estimation of the income element in on-money receipts was a factual determination, not a substantial question of law under Section 260A of the Income-tax Act, 1961. The Tribunal had accepted receipt of on-money, rejected the Revenue&#039;s valuation basis from an email and agreement, and treated the assessee&#039;s admitted rate as a reasonable starting point. It further found that while the entire on-money could not be taxed as income, the absence of evidence of cash expenses outside the books justified a higher estimated percentage. As the findings were based on project accounts, turnover, profit ratio and the nature of the real estate business, no perversity was shown and the appeals failed.</description>
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