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Corporate TaxArticle·25 February 2026

Reaffirming Evidentiary Discipline under Section 44AD

By JustIDT

Executive Summary

This note by J the App, examines a significant ruling of the Income Tax Appellate Tribunal, Agra, concerning the interplay between Section 44AD (presumptive taxation) and Section 68 (unexplained cash credits). The case addresses whether cash sales declared immediately prior to demonetisation can be treated as bogus merely on suspicion and clarifies the evidentiary limits of revenue authorities when income has been offered under the presumptive scheme. The decision carries important implications for small businesses, scrutiny assessments, and litigation strategy involving suspicion-based additions.

Introduction to the Case

The present matter arises from an appeal filed before the Income Tax Appellate Tribunal, Agra (SMC ...

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