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    <title>2025 (3) TMI 2272 - ITAT AGRA</title>
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    <description>Trading-linked cash withdrawals arising from RTGS/NEFT credits could not be treated wholly as unexplained money where their origin in trading activity remained unrebutted. In the absence of an earlier trading-income estimate, income was estimated at 5% of the withdrawals and taxed at normal rates; the higher rate applied only to transactions from 1 April 2017. Cash-deposit additions remained sustainable because no source was established. Penalties were deleted because estimated income alone did not establish concealment of income particulars. Taxable income was to be recomputed using the 5% estimate while retaining the unexplained cash-deposit addition.</description>
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      <description>Trading-linked cash withdrawals arising from RTGS/NEFT credits could not be treated wholly as unexplained money where their origin in trading activity remained unrebutted. In the absence of an earlier trading-income estimate, income was estimated at 5% of the withdrawals and taxed at normal rates; the higher rate applied only to transactions from 1 April 2017. Cash-deposit additions remained sustainable because no source was established. Penalties were deleted because estimated income alone did not establish concealment of income particulars. Taxable income was to be recomputed using the 5% estimate while retaining the unexplained cash-deposit addition.</description>
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