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2023 (10) TMI 1055 - ITAT AHMEDABADAssessment of trust - Unexplained expenditure incurred u/s 69C - excess income applied - Assessee prays that excess expenditure is from out of previous surplus balance and 15% balance accumulation as per section 11 and 12 - HELD THAT:- It is pertinent to note that the “Current Liabilities” mentioned in the annexure-5/schedule of the audited balance sheet of the assessee trust clearly mentioned the name of the said two parties. Thus, the observation of the CIT(A) that the said parties are not mentioned in balance sheet in respect of the borrowing is not correct. Besides this, the assessee trust has also given the details of statement of return of income as well as confirmation of those parties where it appears that the creditworthiness and genuineness has been established by the assessee trust CIT(A) has totally ignored these evidences. Therefore, the addition confirmed by the CIT(A) as relates to Section 69C does not survive. The appeal of the assessee trust is allowed.
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