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    <title>2025 (3) TMI 1971 - ITAT JAIPUR</title>
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    <description>Section 69A of the Income-tax Act, 1961, read with Section 115BBE, concerns unexplained money where ownership is established but the nature and source remain unsubstantiated. The notes explain that the assessee must provide an explanation, while the Revenue must first establish the statutory preconditions with cogent material. An HUF&#039;s ancestral agricultural land, identified cultivators and agricultural rental receipts may support the explanation for cash deposits, particularly where those facts were accepted in the assessment record. The absence of an earlier PAN or return declaration does not, by itself, prove that the HUF was newly created or that exempt agricultural receipts were unexplained. Additions cannot rest solely on presumptions or guesswork.</description>
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    <pubDate>Thu, 13 Mar 2025 00:00:00 +0530</pubDate>
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      <title>2025 (3) TMI 1971 - ITAT JAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=470063</link>
      <description>Section 69A of the Income-tax Act, 1961, read with Section 115BBE, concerns unexplained money where ownership is established but the nature and source remain unsubstantiated. The notes explain that the assessee must provide an explanation, while the Revenue must first establish the statutory preconditions with cogent material. An HUF&#039;s ancestral agricultural land, identified cultivators and agricultural rental receipts may support the explanation for cash deposits, particularly where those facts were accepted in the assessment record. The absence of an earlier PAN or return declaration does not, by itself, prove that the HUF was newly created or that exempt agricultural receipts were unexplained. Additions cannot rest solely on presumptions or guesswork.</description>
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      <pubDate>Thu, 13 Mar 2025 00:00:00 +0530</pubDate>
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