https://www.taxtmi.com/caselaws?id=758394 ITAT Mumbai dismissed revenue's appeal challenging deletion of additions under sections 69 and 69C. The assessee received funds from a third party for property and car purchases. The tribunal held that section 69 provisions cannot apply when payments were made by another person, not the assessee. The assessee satisfactorily explained the nature and source of funds with supporting evidence, including loan confirmation documents. Revenue's alternative argument to tax amounts under section 56(2) as gifts was rejected since this ground was not originally examined by AO or CIT(A), and revenue cannot raise fresh contentions. The tribunal found no undisclosed expenditure warranting additions. en-us Thu, 05 Sep 2024 00:00:00 +0530 Fri, 13 Sep 2024 08:31:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758394 ITAT Mumbai dismissed revenue's appeal challenging deletion of additions under sections 69 and 69C. The assessee received funds from a third party for property and car purchases. The tribunal held that section 69 provisions cannot apply when payments were made by another person, not the assessee. The assessee satisfactorily explained the nature and source of funds with supporting evidence, including loan confirmation documents. Revenue's alternative argument to tax amounts under section 56(2) as gifts was rejected since this ground was not originally examined by AO or CIT(A), and revenue cannot raise fresh contentions. The tribunal found no undisclosed expenditure warranting additions. Case-Laws Income Tax Thu, 05 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758394