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    <title>2023 (12) TMI 327 - ITAT DELHI</title>
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    <description>ITAT Delhi upheld additions for undisclosed loans and advances, finding that seized documents showing loans are subject to section 68 requirements despite presumption under section 132(4A)/292C. Assessee failed to prove identity, capacity, and genuineness of transactions. Tribunal partially allowed appeal regarding undisclosed interest, directing 60:40 allocation between assessee and brother. Deletions by CIT(A) were upheld for jewellery investment (only Rs. 67 lakhs purchased with proper source documentation), undisclosed property investment (sale deed executed in different assessment year), and share purchases (transfer never materialized as original holder remained registered). Interest under section 234A was not charged for period when seized material copies weren&#039;t provided to assessee. Trading commission addition was deleted as it was based solely on confession without supporting evidence.</description>
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    <pubDate>Thu, 27 Apr 2023 00:00:00 +0530</pubDate>
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      <title>2023 (12) TMI 327 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=446643</link>
      <description>ITAT Delhi upheld additions for undisclosed loans and advances, finding that seized documents showing loans are subject to section 68 requirements despite presumption under section 132(4A)/292C. Assessee failed to prove identity, capacity, and genuineness of transactions. Tribunal partially allowed appeal regarding undisclosed interest, directing 60:40 allocation between assessee and brother. Deletions by CIT(A) were upheld for jewellery investment (only Rs. 67 lakhs purchased with proper source documentation), undisclosed property investment (sale deed executed in different assessment year), and share purchases (transfer never materialized as original holder remained registered). Interest under section 234A was not charged for period when seized material copies weren&#039;t provided to assessee. Trading commission addition was deleted as it was based solely on confession without supporting evidence.</description>
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      <pubDate>Thu, 27 Apr 2023 00:00:00 +0530</pubDate>
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