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    <title>2025 (2) TMI 1844 - ITAT NAGPUR</title>
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    <description>A deemed dividend addition under section 2(22)(e) was deleted because the same accumulated profits had already suffered tax, so further taxation would amount to double taxation once those profits were exhausted for that purpose. An estimated rent addition as notional income was also deleted because the premises were used for the assessee&#039;s own business and professional needs, and notional income cannot be assessed without a charging provision. The section 68 addition was deleted because the assessee proved the lender&#039;s identity, genuineness of the transaction, and creditworthiness through tax and bank records. The appellate relief on all disputed additions was upheld.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468657</link>
      <description>A deemed dividend addition under section 2(22)(e) was deleted because the same accumulated profits had already suffered tax, so further taxation would amount to double taxation once those profits were exhausted for that purpose. An estimated rent addition as notional income was also deleted because the premises were used for the assessee&#039;s own business and professional needs, and notional income cannot be assessed without a charging provision. The section 68 addition was deleted because the assessee proved the lender&#039;s identity, genuineness of the transaction, and creditworthiness through tax and bank records. The appellate relief on all disputed additions was upheld.</description>
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