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    <title>2025 (7) TMI 1025 - ITAT AHMEDABAD</title>
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    <description>The ITAT Ahmedabad dismissed the Revenue&#039;s appeal regarding additions under Section 69A for Assessment Years 2014-15 and 2015-16. The AO had treated trading losses as non-genuine investments based solely on general Investigation Wing reports without conducting independent enquiry or identifying specific irregularities. The CIT(A) correctly found that all transactions were supported by documentary evidence with no adverse inference regarding IPO share allotments or subsequent sales. No material demonstrated cash trails, unaccounted receipts, or financial benefits outside recorded books. For AY 2015-16, the AO&#039;s methodology for computing alleged fictitious losses/gains was factually incorrect, as the assessee had realized genuine profits supported by primary evidence. The Tribunal had previously upheld similar LHSL trading transactions&#039; genuineness in AY 2013-14. Without credible evidence establishing fictitious transactions or accommodation entries, the appellate order deleting additions was upheld.</description>
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      <link>https://www.taxtmi.com/caselaws?id=774957</link>
      <description>The ITAT Ahmedabad dismissed the Revenue&#039;s appeal regarding additions under Section 69A for Assessment Years 2014-15 and 2015-16. The AO had treated trading losses as non-genuine investments based solely on general Investigation Wing reports without conducting independent enquiry or identifying specific irregularities. The CIT(A) correctly found that all transactions were supported by documentary evidence with no adverse inference regarding IPO share allotments or subsequent sales. No material demonstrated cash trails, unaccounted receipts, or financial benefits outside recorded books. For AY 2015-16, the AO&#039;s methodology for computing alleged fictitious losses/gains was factually incorrect, as the assessee had realized genuine profits supported by primary evidence. The Tribunal had previously upheld similar LHSL trading transactions&#039; genuineness in AY 2013-14. Without credible evidence establishing fictitious transactions or accommodation entries, the appellate order deleting additions was upheld.</description>
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