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    <title>2024 (1) TMI 753 - CHHATTISGARH HIGH COURT</title>
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    <description>The HC upheld the Tribunal&#039;s decision against revenue in a Section 263 revision case. The PCIT&#039;s revision order was found defective as Section 68 (cash credit addition) could not be invoked for past credits from financial years 2013-14 and 2014-15 that were carried forward. The PCIT violated natural justice by not providing hearing opportunity before classifying the lender as a shell company and relying on undisclosed statements. Section 69C addition was inappropriate as books were reliable and supported by proper vouchers. Section 43CA application was partially upheld only for differences exceeding 10% threshold. The Tribunal&#039;s order raised no substantial question of law warranting HC interference.</description>
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      <link>https://www.taxtmi.com/caselaws?id=448354</link>
      <description>The HC upheld the Tribunal&#039;s decision against revenue in a Section 263 revision case. The PCIT&#039;s revision order was found defective as Section 68 (cash credit addition) could not be invoked for past credits from financial years 2013-14 and 2014-15 that were carried forward. The PCIT violated natural justice by not providing hearing opportunity before classifying the lender as a shell company and relying on undisclosed statements. Section 69C addition was inappropriate as books were reliable and supported by proper vouchers. Section 43CA application was partially upheld only for differences exceeding 10% threshold. The Tribunal&#039;s order raised no substantial question of law warranting HC interference.</description>
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