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ITAT allowed the assessee's appeal, holding that additions under section 69A and section 68 were unsustainable. The Tribunal found the addition under s.69A, alleging unexplained investment in land, legally and factually untenable because the impugned sum was not fully paid in the relevant previous year and the investment source was satisfactorily explained by partners' capital contributions. The Tribunal further held that the addition under s.68, premised on alleged unexplained capital introduced by partners, was unjustified since the assessee had established the partners' identity, creditworthiness and the genuineness of the transactions. Consequently, both additions were deleted and the assessment recalibrated accordingly.
ITAT allowed the assessee's appeal, holding that additions under section 69A and section 68 were unsustainable. The Tribunal found the addition under s.69A, alleging unexplained investment in land, legally and factually untenable because the impugned sum was not fully paid in the relevant previous year and the investment source was satisfactorily explained by partners' capital contributions. The Tribunal further held that the addition under s.68, premised on alleged unexplained capital introduced by partners, was unjustified since the assessee had established the partners' identity, creditworthiness and the genuineness of the transactions. Consequently, both additions were deleted and the assessment recalibrated accordingly.
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