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    <title>2026 (10) TMI 1274 - ITAT KOLKATA</title>
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    <description>Section 68 additions for share capital, premium and unsecured loans were unsustainable where corporate subscribers and lenders provided verified identity, financial capacity, confirmations, audited accounts and banking records, including source-of-funds evidence where examined. Lack of adverse findings in remand verification, repayment of loans, and denial of cross-examination on an undisclosed inspector&#039;s report supported deletion of the additions. Under the Purpose Test, incentives intended to establish or expand industry, create employment and promote regional development were capital receipts rather than operational-profit supplements; they were excluded from normal income computation. Transport subsidy and VAT/CST remission, as receipts not constituting income, were also excluded from book profit for MAT.</description>
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