https://www.taxtmi.com/caselaws?id=774052 ITAT Mumbai upheld CIT(A)'s deletion of disallowance u/s 69C regarding 'Downside on Sale of Flats' expenses. The assessee entered underwriting agreements with developer for flat purchases, bearing risks/rewards. When flats sold to end customers at lower prices, resulting losses were genuine business deductions. ITAT found arrangement was not actual property sale but underwriting agreement. Assessee consistently treated similar transactions, offered profits in previous years which were accepted. All supporting documents including MOUs and bank statements were provided. ITAT also deleted addition u/s 68 for unsecured loans, finding AO's rejection based solely on bank's non-response to notices was insufficient when assessee provided adequate documentation establishing transaction genuineness. en-us Thu, 19 Jun 2025 00:00:00 +0530 Wed, 02 Jul 2025 08:42:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774052 ITAT Mumbai upheld CIT(A)'s deletion of disallowance u/s 69C regarding 'Downside on Sale of Flats' expenses. The assessee entered underwriting agreements with developer for flat purchases, bearing risks/rewards. When flats sold to end customers at lower prices, resulting losses were genuine business deductions. ITAT found arrangement was not actual property sale but underwriting agreement. Assessee consistently treated similar transactions, offered profits in previous years which were accepted. All supporting documents including MOUs and bank statements were provided. ITAT also deleted addition u/s 68 for unsecured loans, finding AO's rejection based solely on bank's non-response to notices was insufficient when assessee provided adequate documentation establishing transaction genuineness. Case-Laws Income Tax Thu, 19 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774052