https://www.taxtmi.com/caselaws?id=782136 ITAT Raipur allowed the assessee's appeal and deleted additions made under s.68 r.w.s. 115BBE on account of partners' capital and disallowance of interest @12% on alleged misutilization of interest-bearing funds. The Tribunal held that AO and CIT(A)/NFAC failed to examine or inquire into the assessee's specific claim that the partner's capital introduction came from available cash in hand generated from earlier withdrawals, despite supporting cash flow and bank statements. It further held that the authorities changed the basis of disallowance without factual inquiry, rendering the additions perverse, arbitrary, and in breach of principles of natural justice and the mandate of s.250(4) & (6). Consequently, all impugned additions were held illegal and unsustainable, and the AO was directed to give appeal effect. en-us Fri, 14 Nov 2025 00:00:00 +0530 Tue, 25 Nov 2025 08:55:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782136 ITAT Raipur allowed the assessee's appeal and deleted additions made under s.68 r.w.s. 115BBE on account of partners' capital and disallowance of interest @12% on alleged misutilization of interest-bearing funds. The Tribunal held that AO and CIT(A)/NFAC failed to examine or inquire into the assessee's specific claim that the partner's capital introduction came from available cash in hand generated from earlier withdrawals, despite supporting cash flow and bank statements. It further held that the authorities changed the basis of disallowance without factual inquiry, rendering the additions perverse, arbitrary, and in breach of principles of natural justice and the mandate of s.250(4) & (6). Consequently, all impugned additions were held illegal and unsustainable, and the AO was directed to give appeal effect. Case-Laws Income Tax Fri, 14 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782136