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2014 (8) TMI 958 - ITAT DELHIDisallowance u/s 68 - Admission of additional evidence - Held that:- AO ignored the very fact that the amount of ₹ 16,22,140 received by the assessee from her clients was further deposited into respective saving accounts of her clients and this amount cannot be treated as income of the assessee, hence protective addition u/s 68 of the Act is not sustainable. - observations of the AO in the assessment order and remand report were made ignoring the entire modus operandi and working of the assessee and her husband as amount received from their clients for further deposition cannot be said to be income in the hands of assessee and protective addition u/s 68 of the Act is not justified under these circumstances. Therefore, we are of the considered view that the CIT(A) was right in deleting the addition made u/s 68 of the Act on protective basis and we are unable to see any valid reason to interfere with the same - Decided against Revenue.
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