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    <title>2024 (12) TMI 806 - ITAT DELHI</title>
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    <description>The ITAT Delhi ruled in favor of a UK-resident doctor regarding unexplained cash deposits totaling substantial amounts in Federal Bank during demonetization period (November-December 2016). The assessee claimed deposits were gifts from family members (parents, brother, sister-in-law) who are doctors with substantial declared incomes. The ITAT held that after the assessee provided explanation with gift certificates, the onus shifted to the AO to conduct further enquiries under sections 133(6)/131(1) with family members. The AO failed to verify the genuineness of transactions and relied on conjectures without proper investigation. The addition under section 68 read with 115BBE was deleted, though the ITAT noted that non-specification of exact section doesn&#039;t render assessment arbitrary when nature of addition was communicated.</description>
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      <title>2024 (12) TMI 806 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=763226</link>
      <description>The ITAT Delhi ruled in favor of a UK-resident doctor regarding unexplained cash deposits totaling substantial amounts in Federal Bank during demonetization period (November-December 2016). The assessee claimed deposits were gifts from family members (parents, brother, sister-in-law) who are doctors with substantial declared incomes. The ITAT held that after the assessee provided explanation with gift certificates, the onus shifted to the AO to conduct further enquiries under sections 133(6)/131(1) with family members. The AO failed to verify the genuineness of transactions and relied on conjectures without proper investigation. The addition under section 68 read with 115BBE was deleted, though the ITAT noted that non-specification of exact section doesn&#039;t render assessment arbitrary when nature of addition was communicated.</description>
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