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    <title>2025 (3) TMI 935 - DELHI HIGH COURT</title>
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    <description>The Delhi HC upheld ITAT&#039;s decision to delete addition u/s 68 of the Income Tax Act. The AO had made additions despite having all requisite information about shareholders, but recorded findings without proper reasoning. Both CIT(A) and ITAT concurrently found that existing shareholders satisfied the triple test under section 68 - identity, genuineness, and creditworthiness were established. The shareholders had sufficient exempt income and disclosed past transactions. The HC refused to interfere with appellate authorities&#039; factual findings, noting the AO&#039;s conclusions were contrary to available record and perverse for lack of supporting reasons.</description>
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    <pubDate>Mon, 03 Mar 2025 00:00:00 +0530</pubDate>
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      <title>2025 (3) TMI 935 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=767549</link>
      <description>The Delhi HC upheld ITAT&#039;s decision to delete addition u/s 68 of the Income Tax Act. The AO had made additions despite having all requisite information about shareholders, but recorded findings without proper reasoning. Both CIT(A) and ITAT concurrently found that existing shareholders satisfied the triple test under section 68 - identity, genuineness, and creditworthiness were established. The shareholders had sufficient exempt income and disclosed past transactions. The HC refused to interfere with appellate authorities&#039; factual findings, noting the AO&#039;s conclusions were contrary to available record and perverse for lack of supporting reasons.</description>
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