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    <title>2025 (5) TMI 2119 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai dismissed Revenue&#039;s appeal regarding addition under section 68 for alleged bogus unsecured loan of INR 4 crore. The tribunal found the amount was received from legitimate sale of 40,00,000 CCDs to another company, not accommodation entry transaction as claimed by Revenue based solely on unsubstantiated search statements. Consequently, addition under section 69C for commission payment was also deleted. Additionally, ITAT upheld CIT(A)&#039;s deletion of section 14A disallowance, ruling that applying Rule 8D over assessee&#039;s suo motu disallowance would impermissibly add non-existing expenditure not debited in profit and loss account.</description>
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      <link>https://www.taxtmi.com/caselaws?id=771847</link>
      <description>ITAT Mumbai dismissed Revenue&#039;s appeal regarding addition under section 68 for alleged bogus unsecured loan of INR 4 crore. The tribunal found the amount was received from legitimate sale of 40,00,000 CCDs to another company, not accommodation entry transaction as claimed by Revenue based solely on unsubstantiated search statements. Consequently, addition under section 69C for commission payment was also deleted. Additionally, ITAT upheld CIT(A)&#039;s deletion of section 14A disallowance, ruling that applying Rule 8D over assessee&#039;s suo motu disallowance would impermissibly add non-existing expenditure not debited in profit and loss account.</description>
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