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    <title>2024 (12) TMI 861 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad ruled in favor of the assessee on multiple grounds. The tribunal deleted proportionate interest expense disallowance, finding sufficient interest-free funds existed and no direct nexus between borrowed funds and non-income generating investments was established by AO. Additions under Section 68 for unexplained cash credits were deleted as assessee adequately proved identity, genuineness and creditworthiness of lenders while AO failed to verify through proper notices. Cost of improvement disallowance was restricted to 10% due to partial documentation concerns. Bogus gift receipt addition was deleted after assessee provided adequate supporting documents establishing donor&#039;s creditworthiness and transaction genuineness.</description>
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      <link>https://www.taxtmi.com/caselaws?id=763281</link>
      <description>ITAT Ahmedabad ruled in favor of the assessee on multiple grounds. The tribunal deleted proportionate interest expense disallowance, finding sufficient interest-free funds existed and no direct nexus between borrowed funds and non-income generating investments was established by AO. Additions under Section 68 for unexplained cash credits were deleted as assessee adequately proved identity, genuineness and creditworthiness of lenders while AO failed to verify through proper notices. Cost of improvement disallowance was restricted to 10% due to partial documentation concerns. Bogus gift receipt addition was deleted after assessee provided adequate supporting documents establishing donor&#039;s creditworthiness and transaction genuineness.</description>
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