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    <title>2025 (7) TMI 1029 - ITAT DELHI</title>
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    <description>The ITAT Delhi upheld the CIT(A)&#039;s decision to delete additions made under section 68 for unexplained cash credit. The Revenue&#039;s reopening of assessment was held invalid as it was based on borrowed satisfaction without proper reasons to believe. The tribunal found that the lender company had already been assessed for the same funds as unexplained cash credit in AY 2008-09, and this assessment remained unchallenged. The assessee successfully argued that once additions were made in the hands of the lender company, the same amount could not be added again in the borrower&#039;s hands, as this would constitute double taxation. The tribunal ruled that the identity and creditworthiness of the lender were established to the required extent since the Revenue had already made additions in the lender&#039;s case. Both the additional ground regarding invalid reopening and the original grounds on merits were dismissed.</description>
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    <pubDate>Wed, 18 Jun 2025 00:00:00 +0530</pubDate>
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      <title>2025 (7) TMI 1029 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=774961</link>
      <description>The ITAT Delhi upheld the CIT(A)&#039;s decision to delete additions made under section 68 for unexplained cash credit. The Revenue&#039;s reopening of assessment was held invalid as it was based on borrowed satisfaction without proper reasons to believe. The tribunal found that the lender company had already been assessed for the same funds as unexplained cash credit in AY 2008-09, and this assessment remained unchallenged. The assessee successfully argued that once additions were made in the hands of the lender company, the same amount could not be added again in the borrower&#039;s hands, as this would constitute double taxation. The tribunal ruled that the identity and creditworthiness of the lender were established to the required extent since the Revenue had already made additions in the lender&#039;s case. Both the additional ground regarding invalid reopening and the original grounds on merits were dismissed.</description>
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      <pubDate>Wed, 18 Jun 2025 00:00:00 +0530</pubDate>
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