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    <title>2026 (6) TMI 1457 - GUJARAT HIGH COURT</title>
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    <description>Concurrent factual findings that two related partnership firms with separate PANs, audit reports and books had already disclosed and taxed the same income in consolidated accounts barred a further addition in one firm&#039;s hands. The Gujarat HC accepted that the arrangement was for business convenience and subsidy-related purposes, and found no escapement of income or loss to the Revenue. As no substantial question of law arose from those findings, the additions were held unsustainable and the Revenue&#039;s challenge failed.</description>
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      <description>Concurrent factual findings that two related partnership firms with separate PANs, audit reports and books had already disclosed and taxed the same income in consolidated accounts barred a further addition in one firm&#039;s hands. The Gujarat HC accepted that the arrangement was for business convenience and subsidy-related purposes, and found no escapement of income or loss to the Revenue. As no substantial question of law arose from those findings, the additions were held unsustainable and the Revenue&#039;s challenge failed.</description>
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