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    <title>2025 (3) TMI 2308 - ITAT RAJKOT</title>
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    <description>Derivative-trading ledger credits were assessable only to the established profit element, not on a peak-credit basis. Reconciled STCSH metal, cash and premium entries, foreign-account KYC declarations, cheque transactions, RAK Bank remittances, dairy-farm receipts, excess bullion stock and advance notings lacked evidence of unaccounted income or would have caused double taxation; the related additions were deleted. Interest expenditure remained allowable because diversion of borrowed funds for non-business purposes was not proved. Notional rental income and premature unit-linked insurance policy surrender proceeds remained taxable. Unexplained non-settlement credits in the Standard Bank cash ledger remained taxable under Section 69A because their source and claimed third-party ownership were unsupported.</description>
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      <description>Derivative-trading ledger credits were assessable only to the established profit element, not on a peak-credit basis. Reconciled STCSH metal, cash and premium entries, foreign-account KYC declarations, cheque transactions, RAK Bank remittances, dairy-farm receipts, excess bullion stock and advance notings lacked evidence of unaccounted income or would have caused double taxation; the related additions were deleted. Interest expenditure remained allowable because diversion of borrowed funds for non-business purposes was not proved. Notional rental income and premature unit-linked insurance policy surrender proceeds remained taxable. Unexplained non-settlement credits in the Standard Bank cash ledger remained taxable under Section 69A because their source and claimed third-party ownership were unsupported.</description>
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