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    <title>2023 (11) TMI 1462 - ITAT BANGALORE</title>
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    <description>Cash deposits during the demonetisation period may be assessed as unexplained investment under section 69 where the taxpayer fails to establish their source. Small ATM withdrawals made over an extended period, substantially before the deposits, may reasonably be treated as personal or family expenditure rather than cash retained for a later large deposit. The claimed custody of cash requires substantiation. Section 69 uses discretionary language, but its application is justified when deposits are not explained under an identifiable head of income. On these facts, the deposits were treated as unexplained investment against the taxpayer.</description>
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      <title>2023 (11) TMI 1462 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=471977</link>
      <description>Cash deposits during the demonetisation period may be assessed as unexplained investment under section 69 where the taxpayer fails to establish their source. Small ATM withdrawals made over an extended period, substantially before the deposits, may reasonably be treated as personal or family expenditure rather than cash retained for a later large deposit. The claimed custody of cash requires substantiation. Section 69 uses discretionary language, but its application is justified when deposits are not explained under an identifiable head of income. On these facts, the deposits were treated as unexplained investment against the taxpayer.</description>
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      <pubDate>Tue, 28 Nov 2023 00:00:00 +0530</pubDate>
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