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    <title>2026 (11) TMI 334 - ITAT MUMBAI</title>
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    <description>Section 69 applies to investments made during the relevant financial year whose nature and source are not satisfactorily explained. The tax authority must first establish the investments made during that year and their amount; the taxpayer must then explain their nature and source. A year-end asset disclosure may reflect cumulative holdings, including earlier investments. An addition cannot be sustained solely on that disclosure without determining the investments made during the year and examining admitted evidence of investment movements. The investments and their nature and source require fresh determination.</description>
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      <description>Section 69 applies to investments made during the relevant financial year whose nature and source are not satisfactorily explained. The tax authority must first establish the investments made during that year and their amount; the taxpayer must then explain their nature and source. A year-end asset disclosure may reflect cumulative holdings, including earlier investments. An addition cannot be sustained solely on that disclosure without determining the investments made during the year and examining admitted evidence of investment movements. The investments and their nature and source require fresh determination.</description>
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