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    <title>2026 (6) TMI 281 - ITAT DELHI</title>
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    <description>Section 68 could not be applied to partners&#039; capital recorded only as a notional journal entry, because there was no actual receipt of funds and the partners&#039; identity was established, so the addition was deleted. Administrative expenditure incurred after the LLP had been set up and was ready to commence business remained allowable even though no revenue was earned during the year, so the disallowance was deleted. As the main additions did not survive, the consequential tax, interest, and penalty based on those additions also ceased to survive.</description>
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      <description>Section 68 could not be applied to partners&#039; capital recorded only as a notional journal entry, because there was no actual receipt of funds and the partners&#039; identity was established, so the addition was deleted. Administrative expenditure incurred after the LLP had been set up and was ready to commence business remained allowable even though no revenue was earned during the year, so the disallowance was deleted. As the main additions did not survive, the consequential tax, interest, and penalty based on those additions also ceased to survive.</description>
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