Asset Revaluation and Capital Account Credit Without Transfer Not Taxable Under Section 68; Brokerage Expenses Allowed

ITAT dismissed Revenue's appeal regarding additions under Section 68 and brokerage expense disallowance. The Tribunal held that revaluation of assets by AOP (DD Associates) and subsequent credit to assessee's capital account did not trigger taxable income, as no actual transfer or sale occurred. The revaluation merely recognized present value in books without creating tax liability. The share adjustment from 46.50% to 5% was legitimate accounting entry, not a tax avoidance scheme. Regarding brokerage expenses, ITAT upheld CIT(A)'s deletion of disallowance since payments were made via cheque with TDS deduction and specific purpose was established. Both grounds decided in assessee's favor. .....

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