ITAT Deletes LTCG Addition as “Human Probability” Can’t Replace Evidence

Archit Gupta Vs ACIT (ITAT Delhi) ITAT Delhi deletes ₹47 lakh bogus LTCG addition – “human probability” cannot override documentary proof Delhi Tribunal deleted the addition of ₹47.22 lakh made u/s 68 on alleged bogus Long-Term Capital Gain (LTCG) from shares of Goenka Business & Finance Ltd. AO treated the LTCG as accommodation entry citing investigation reports & “penny stock” features. However, Tribunal noted that all transactions were through stock exchange, demat account, banking channels, & subject to STT, and that no evidence linked Assessee with any entry oper...