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    <title>1997 (11) TMI 118 - ITAT AHMEDABAD-A</title>
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    <description>The Tribunal found that the Revenue failed to prove that the amounts received were borrowed funds used for income-earning activities. The AO did not provide evidence of income generation from these funds. The CIT(A)&#039;s estimation of income at 12% was deemed baseless. Consequently, the Tribunal deleted the additions sustained by the CIT(A) for the assessment years. The issue of charging interest under sections 139(8) and 217 was remanded to the AO for a fresh decision, ensuring the assessee is heard.</description>
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    <pubDate>Mon, 03 Nov 1997 00:00:00 +0530</pubDate>
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      <title>1997 (11) TMI 118 - ITAT AHMEDABAD-A</title>
      <link>https://www.taxtmi.com/caselaws?id=55559</link>
      <description>The Tribunal found that the Revenue failed to prove that the amounts received were borrowed funds used for income-earning activities. The AO did not provide evidence of income generation from these funds. The CIT(A)&#039;s estimation of income at 12% was deemed baseless. Consequently, the Tribunal deleted the additions sustained by the CIT(A) for the assessment years. The issue of charging interest under sections 139(8) and 217 was remanded to the AO for a fresh decision, ensuring the assessee is heard.</description>
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      <pubDate>Mon, 03 Nov 1997 00:00:00 +0530</pubDate>
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