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    <title>2023 (9) TMI 1420 - ITAT BANGALORE</title>
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    <description>The ITAT Bangalore ruled on a section 153A assessment involving multiple additions. The tribunal held that without incriminating material, no addition can be made in completed assessments, citing jurisdictional HC precedents. For section 68 additions, the opening balance of Rs. 64,72,071 was deleted as it related to earlier assessment years with TDS already deducted, but sustained Rs. 39,85,184 addition as the assessee voluntarily offered unexplained income. Consultancy charges disallowance was reversed due to AO&#039;s failure to conduct proper enquiry. Interest deduction under section 36(1)(iii) worth Rs. 34,80,353 was upheld as disallowed since borrowed funds were used for interest-free advances rather than business purposes.</description>
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    <pubDate>Fri, 29 Sep 2023 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=311616</link>
      <description>The ITAT Bangalore ruled on a section 153A assessment involving multiple additions. The tribunal held that without incriminating material, no addition can be made in completed assessments, citing jurisdictional HC precedents. For section 68 additions, the opening balance of Rs. 64,72,071 was deleted as it related to earlier assessment years with TDS already deducted, but sustained Rs. 39,85,184 addition as the assessee voluntarily offered unexplained income. Consultancy charges disallowance was reversed due to AO&#039;s failure to conduct proper enquiry. Interest deduction under section 36(1)(iii) worth Rs. 34,80,353 was upheld as disallowed since borrowed funds were used for interest-free advances rather than business purposes.</description>
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