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    <title>2026 (1) TMI 363 - ITAT MUMBAI</title>
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    <description>Where share application money for privately placed preference shares was received but statutory notices to applicants were returned unserved and applicants did not respond, the tribunal held the assessee must establish identity, creditworthiness, and genuineness with credible particulars, including current addresses and allotment details; since evidence came only from the assessee and it failed to prove the nature and source beyond doubt, the addition under s.68 was sustained and the corresponding 5% commission addition under s.69C was also sustained. On disallowance under s.14A, applying HC precedent that disallowance cannot exceed exempt income, the AO was directed to cap disallowance at the exempt dividend income, with no further disallowance if already made.</description>
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      <title>2026 (1) TMI 363 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=784607</link>
      <description>Where share application money for privately placed preference shares was received but statutory notices to applicants were returned unserved and applicants did not respond, the tribunal held the assessee must establish identity, creditworthiness, and genuineness with credible particulars, including current addresses and allotment details; since evidence came only from the assessee and it failed to prove the nature and source beyond doubt, the addition under s.68 was sustained and the corresponding 5% commission addition under s.69C was also sustained. On disallowance under s.14A, applying HC precedent that disallowance cannot exceed exempt income, the AO was directed to cap disallowance at the exempt dividend income, with no further disallowance if already made.</description>
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