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    <title>2023 (12) TMI 391 - ITAT DELHI</title>
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    <description>ITAT Delhi allowed assessee&#039;s appeal regarding addition u/s 69 for unexplained investments, holding that treating account &quot;AP&quot; as belonging to assessee was based on presumption without recording assessee&#039;s statement. The account showed various acronyms indicating transactions neither through bank nor cash, making inference to assessee unwarranted. Peak credit theory by CIT(A) became infructuous. For gold sale addition, ITAT directed AO to compute 2% profit instead of full amount. CIT(A)&#039;s order on other u/s 69 additions was upheld. Trail balance profit addition was sustained only to extent of Rs. 1,16,365/- as cash payment without corroborative evidence of dabba trading business.</description>
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    <pubDate>Wed, 02 Aug 2023 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=446707</link>
      <description>ITAT Delhi allowed assessee&#039;s appeal regarding addition u/s 69 for unexplained investments, holding that treating account &quot;AP&quot; as belonging to assessee was based on presumption without recording assessee&#039;s statement. The account showed various acronyms indicating transactions neither through bank nor cash, making inference to assessee unwarranted. Peak credit theory by CIT(A) became infructuous. For gold sale addition, ITAT directed AO to compute 2% profit instead of full amount. CIT(A)&#039;s order on other u/s 69 additions was upheld. Trail balance profit addition was sustained only to extent of Rs. 1,16,365/- as cash payment without corroborative evidence of dabba trading business.</description>
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