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    <title>2025 (7) TMI 765 - DELHI HIGH COURT</title>
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    <description>Delhi HC dismissed Revenue&#039;s appeal against ITAT&#039;s decision regarding addition under section 68 for share capital received from three companies. AO had issued notices under section 133(6) to share applicants who failed to respond. ITAT found investors had confirmed their investments with no allegation that capital receipts were Assessee&#039;s own money. HC held that even accepting Revenue&#039;s contention that Assessee was a conduit for fund transfers, the receipts wouldn&#039;t constitute Assessee&#039;s income. The source explanation issue was factual, and ITAT&#039;s findings raised no substantial question of law warranting HC&#039;s consideration.</description>
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      <title>2025 (7) TMI 765 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=774697</link>
      <description>Delhi HC dismissed Revenue&#039;s appeal against ITAT&#039;s decision regarding addition under section 68 for share capital received from three companies. AO had issued notices under section 133(6) to share applicants who failed to respond. ITAT found investors had confirmed their investments with no allegation that capital receipts were Assessee&#039;s own money. HC held that even accepting Revenue&#039;s contention that Assessee was a conduit for fund transfers, the receipts wouldn&#039;t constitute Assessee&#039;s income. The source explanation issue was factual, and ITAT&#039;s findings raised no substantial question of law warranting HC&#039;s consideration.</description>
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