https://www.taxtmi.com/caselaws?id=773885 ITAT Mumbai held that addition under Section 68 read with Section 115BBE for unexplained credit was unjustified when a private company converted to LLP and transferred share capital and reserves to partners' accounts. The AO incorrectly applied Section 68 despite alleging violation of Section 47(xiiib)(f) conditions. The tribunal found that Section 47 relates only to capital gains computation under Section 45, not unexplained credits. Since the nature and source of transferred amounts were evident and credits were in partners' accounts rather than assessee's books, Section 68 provisions were not attracted. CIT(A)'s deletion of addition was upheld. en-us Wed, 18 Jun 2025 00:00:00 +0530 Mon, 30 Jun 2025 08:43:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773885 ITAT Mumbai held that addition under Section 68 read with Section 115BBE for unexplained credit was unjustified when a private company converted to LLP and transferred share capital and reserves to partners' accounts. The AO incorrectly applied Section 68 despite alleging violation of Section 47(xiiib)(f) conditions. The tribunal found that Section 47 relates only to capital gains computation under Section 45, not unexplained credits. Since the nature and source of transferred amounts were evident and credits were in partners' accounts rather than assessee's books, Section 68 provisions were not attracted. CIT(A)'s deletion of addition was upheld. Case-Laws Income Tax Wed, 18 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773885