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    <title>2024 (4) TMI 922 - ITAT BANGALORE</title>
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    <description>Advancing funds for a property purchase did not, by itself, justify taxing the financier as the real purchaser or owner. The Revenue had to prove a benami or colourable arrangement with cogent evidence, including control, possession, title custody, motive, and surrounding circumstances, and that burden was not discharged. The sale deeds stood in the name of Shri T. Nadakrishna, so the alleged business income addition in the assessee&#039;s hands was deleted. Because the substantive addition failed, the connected protective addition in Shri T. Nadakrishna&#039;s hands could not be mechanically sustained and was remitted for fresh adjudication on merits after hearing the parties.</description>
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      <title>2024 (4) TMI 922 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=751741</link>
      <description>Advancing funds for a property purchase did not, by itself, justify taxing the financier as the real purchaser or owner. The Revenue had to prove a benami or colourable arrangement with cogent evidence, including control, possession, title custody, motive, and surrounding circumstances, and that burden was not discharged. The sale deeds stood in the name of Shri T. Nadakrishna, so the alleged business income addition in the assessee&#039;s hands was deleted. Because the substantive addition failed, the connected protective addition in Shri T. Nadakrishna&#039;s hands could not be mechanically sustained and was remitted for fresh adjudication on merits after hearing the parties.</description>
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