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    <title>2025 (12) TMI 856 - ITAT DELHI</title>
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    <description>ITAT Delhi held that the addition towards alleged unexplained foreign investment in the names of the assessee&#039;s minor daughters was unsustainable. The Tribunal noted that the assessee, a high-income taxpayer, had sufficient explained income, had duly disclosed the foreign investments in Schedule FA of the return, and had furnished complete particulars of related bank accounts in India and abroad. Consequently, the deletion of the addition by CIT(A) was upheld. On the issue of double taxation relief, ITAT observed that the assessee had properly disclosed foreign income in Schedules FSI and TR/ TY, filed Form 67, and substantiated tax paid in Singapore. The AO was directed to grant relief under sections 90/91.</description>
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      <title>2025 (12) TMI 856 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=783316</link>
      <description>ITAT Delhi held that the addition towards alleged unexplained foreign investment in the names of the assessee&#039;s minor daughters was unsustainable. The Tribunal noted that the assessee, a high-income taxpayer, had sufficient explained income, had duly disclosed the foreign investments in Schedule FA of the return, and had furnished complete particulars of related bank accounts in India and abroad. Consequently, the deletion of the addition by CIT(A) was upheld. On the issue of double taxation relief, ITAT observed that the assessee had properly disclosed foreign income in Schedules FSI and TR/ TY, filed Form 67, and substantiated tax paid in Singapore. The AO was directed to grant relief under sections 90/91.</description>
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