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    <title>2026 (7) TMI 427 - ITAT MUMBAI</title>
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    <description>Deposits in the bank accounts of separate foreign companies could not be assessed as unexplained money in the assessee&#039;s hands under section 69A absent cogent evidence of beneficial ownership, direct flow of funds, or proof that the entities were a mere facade. Past shareholding, directorship, or authority to operate accounts was held insufficient, and the assessee&#039;s explanation supported by confirmations was accepted. The related penalty under section 271(1)(c) also could not survive once the quantum addition was deleted, because it rested entirely on the same addition. The Revenue&#039;s appeals were dismissed and the deletions were left undisturbed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794541</link>
      <description>Deposits in the bank accounts of separate foreign companies could not be assessed as unexplained money in the assessee&#039;s hands under section 69A absent cogent evidence of beneficial ownership, direct flow of funds, or proof that the entities were a mere facade. Past shareholding, directorship, or authority to operate accounts was held insufficient, and the assessee&#039;s explanation supported by confirmations was accepted. The related penalty under section 271(1)(c) also could not survive once the quantum addition was deleted, because it rested entirely on the same addition. The Revenue&#039;s appeals were dismissed and the deletions were left undisturbed.</description>
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