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    <title>2026 (6) TMI 1446 - ITAT DELHI</title>
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    <description>In completed assessments under section 153A, additions must rest on incriminating material found during search; the ITAT held that an alleged unexplained investment based only on a sale deed was unsustainable because the assessee had supporting purchase and lender documents, and a third-party agreement to sell could not by itself justify an addition in the assessee&#039;s hands without independent corroboration. The Tribunal also rejected grossing up of receipts and denial of section 44AD benefits where no seized material supported the enhancement. The Revenue&#039;s appeal failed in full, and the relief granted to the assessee was maintained.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794065</link>
      <description>In completed assessments under section 153A, additions must rest on incriminating material found during search; the ITAT held that an alleged unexplained investment based only on a sale deed was unsustainable because the assessee had supporting purchase and lender documents, and a third-party agreement to sell could not by itself justify an addition in the assessee&#039;s hands without independent corroboration. The Tribunal also rejected grossing up of receipts and denial of section 44AD benefits where no seized material supported the enhancement. The Revenue&#039;s appeal failed in full, and the relief granted to the assessee was maintained.</description>
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