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    <title>2004 (3) TMI 335 - ITAT DELHI-A</title>
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    <description>The Tribunal allowed the appeals of the assessee, determining that the unsecured loan transaction was not a sham and that the assessee successfully discharged its onus under Section 68. The Tribunal found insufficient evidence from the Revenue to label the transaction as a sham and noted that the creditor was identified and had financial capacity. Consequently, the Tribunal deleted the impugned additions. The issue regarding the assumption of jurisdiction under Section 148 was not adjudicated, as it was deemed academic following the decision on the merits.</description>
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      <title>2004 (3) TMI 335 - ITAT DELHI-A</title>
      <link>https://www.taxtmi.com/caselaws?id=63280</link>
      <description>The Tribunal allowed the appeals of the assessee, determining that the unsecured loan transaction was not a sham and that the assessee successfully discharged its onus under Section 68. The Tribunal found insufficient evidence from the Revenue to label the transaction as a sham and noted that the creditor was identified and had financial capacity. Consequently, the Tribunal deleted the impugned additions. The issue regarding the assumption of jurisdiction under Section 148 was not adjudicated, as it was deemed academic following the decision on the merits.</description>
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