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    <title>2021 (12) TMI 206 - GUAJRAT HIGH COURT</title>
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    <description>The High Court upheld the findings of the CIT Appeals and ITAT, ruling that the addition of Rs. 4 Crores under Section 68 of the Income Tax Act was unjustified. The court held that the burden of proof was not met by the AO, emphasizing the lack of credible evidence linking the cash transactions to the assessee. The reopening of the assessment was deemed procedurally correct but failed to substantiate the addition. The appeal by the Revenue was dismissed, highlighting the necessity for substantial proof to support such additions under Section 68.</description>
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      <description>The High Court upheld the findings of the CIT Appeals and ITAT, ruling that the addition of Rs. 4 Crores under Section 68 of the Income Tax Act was unjustified. The court held that the burden of proof was not met by the AO, emphasizing the lack of credible evidence linking the cash transactions to the assessee. The reopening of the assessment was deemed procedurally correct but failed to substantiate the addition. The appeal by the Revenue was dismissed, highlighting the necessity for substantial proof to support such additions under Section 68.</description>
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