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    <title>2026 (7) TMI 499 - ITAT RAIPUR</title>
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    <description>Cash-deposit additions were held unsustainable where the Revenue proceeded on an incorrect charging provision and failed to apply the statutory ingredients to the facts. The Tribunal noted that the assessment and first appellate order treated the deposits as taxable under Section 68 without a coherent factual enquiry into source and nature, and that this reflected non-application of mind. Applying co-ordinate Bench decisions and the principle of consistency, it held that an assessment framed on a wrong and misplaced provision, without sound reasoning, is arbitrary and bad in law. The addition and appellate order were quashed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794613</link>
      <description>Cash-deposit additions were held unsustainable where the Revenue proceeded on an incorrect charging provision and failed to apply the statutory ingredients to the facts. The Tribunal noted that the assessment and first appellate order treated the deposits as taxable under Section 68 without a coherent factual enquiry into source and nature, and that this reflected non-application of mind. Applying co-ordinate Bench decisions and the principle of consistency, it held that an assessment framed on a wrong and misplaced provision, without sound reasoning, is arbitrary and bad in law. The addition and appellate order were quashed.</description>
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