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    <title>2026 (9) TMI 981 - ITAT MUMBAI</title>
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    <description>Unproved accommodation-entry purchases cannot be subjected merely to an estimated profit-rate disallowance when their non-genuine nature is accepted; the purchases must be allowed or disallowed in full. Accordingly, full additions were restored for assessment years 2013-14 and 2014-15, while restricted additions for earlier years remained undisturbed because the Revenue had not contested them. Settlement Commission findings are conclusive only for matters and assessment years before it and cannot determine additions for later years. Search-based additions require independent factual examination. Because relied-upon material was not fully supplied and cross-examination was denied, the remaining additions for later years require fresh assessment after disclosure and adequate hearing.</description>
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      <link>https://www.taxtmi.com/caselaws?id=798955</link>
      <description>Unproved accommodation-entry purchases cannot be subjected merely to an estimated profit-rate disallowance when their non-genuine nature is accepted; the purchases must be allowed or disallowed in full. Accordingly, full additions were restored for assessment years 2013-14 and 2014-15, while restricted additions for earlier years remained undisturbed because the Revenue had not contested them. Settlement Commission findings are conclusive only for matters and assessment years before it and cannot determine additions for later years. Search-based additions require independent factual examination. Because relied-upon material was not fully supplied and cross-examination was denied, the remaining additions for later years require fresh assessment after disclosure and adequate hearing.</description>
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