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    <title>2025 (6) TMI 1545 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad held that addition under section 69 read with section 115BBE for unexplained investment was unjustified. The assessee successfully explained capital introduction in partnership firm as loan from father through banking channels with complete fund trail. Father&#039;s source was substantiated through documented share sale on recognized stock exchange. Revenue failed to provide independent material to discredit explanation or prove undisclosed income. Without evidence of collusion or accommodation, explanation cannot be rejected on mere suspicion. Both essential conditions under section 69 remained unfulfilled as investment was properly recorded and source satisfactorily explained through documentary evidence. CIT(A)&#039;s deletion of addition was upheld.</description>
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    <pubDate>Wed, 18 Jun 2025 00:00:00 +0530</pubDate>
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      <title>2025 (6) TMI 1545 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=773432</link>
      <description>ITAT Ahmedabad held that addition under section 69 read with section 115BBE for unexplained investment was unjustified. The assessee successfully explained capital introduction in partnership firm as loan from father through banking channels with complete fund trail. Father&#039;s source was substantiated through documented share sale on recognized stock exchange. Revenue failed to provide independent material to discredit explanation or prove undisclosed income. Without evidence of collusion or accommodation, explanation cannot be rejected on mere suspicion. Both essential conditions under section 69 remained unfulfilled as investment was properly recorded and source satisfactorily explained through documentary evidence. CIT(A)&#039;s deletion of addition was upheld.</description>
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