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    <title>2026 (2) TMI 161 - ITAT MUMBAI</title>
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    <description>Addition under section 68 for accommodation entries was rejected because the necessary jurisdictional fact -- a sum credited in the books during the relevant year -- was absent. Ledger accounts produced by the taxpayer showed no receipt in the impugned year and the assessing officer produced no material to contradict those ledgers. Reliance solely on information from the Investigation Wing and statements recorded during search, without correlation to book entries, was insufficient. Repetition of the same addition already reflected in another assessment year would cause double taxation; consequently the addition was not sustained in favour of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=785966</link>
      <description>Addition under section 68 for accommodation entries was rejected because the necessary jurisdictional fact -- a sum credited in the books during the relevant year -- was absent. Ledger accounts produced by the taxpayer showed no receipt in the impugned year and the assessing officer produced no material to contradict those ledgers. Reliance solely on information from the Investigation Wing and statements recorded during search, without correlation to book entries, was insufficient. Repetition of the same addition already reflected in another assessment year would cause double taxation; consequently the addition was not sustained in favour of the assessee.</description>
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