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    <title>2024 (12) TMI 1812 - ITAT CHENNAI</title>
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    <description>Section 69 applies only to unexplained investments made during the relevant year; deposits evidenced as pre-existing opening balances fall outside its scope. Financial extracts drawn from accounting records seized during search are not fresh additional evidence under Rule 46A where the underlying records were already available and the figures remain undisputed. Section 69C requires proof that expenditure was actually incurred, not merely that liabilities were recorded as payable. Interest on unrecoverable loan principal is hypothetical rather than real income, and income must be assessed in the hands of the person or entity to whom it belongs.</description>
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      <title>2024 (12) TMI 1812 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=472101</link>
      <description>Section 69 applies only to unexplained investments made during the relevant year; deposits evidenced as pre-existing opening balances fall outside its scope. Financial extracts drawn from accounting records seized during search are not fresh additional evidence under Rule 46A where the underlying records were already available and the figures remain undisputed. Section 69C requires proof that expenditure was actually incurred, not merely that liabilities were recorded as payable. Interest on unrecoverable loan principal is hypothetical rather than real income, and income must be assessed in the hands of the person or entity to whom it belongs.</description>
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