ITAT Mumbai: Partner Capital Not Taxable u/s 68; Source Not Firm’s Burden; ₹19.06 Cr Addition Deleted

MKF International Vs DCIT (ITAT Mumbai) Partner Capital Not Taxable U/s 68 in Firm’s Hands – Source of Partner Funds Not Firm’s Burden – ₹19.06 Cr Addition Deleted – ITAT Mumbai The AO treated capital contribution of ₹19.06 Cr introduced by partners (including NRI partners) as unexplained cash credit u/s 68 and taxed it u/s 115BBE, alleging failure to explain the ultimate source of foreign remittances. CIT(A) confirmed the addition. ITAT held that capital introduced by partners stands on a different legal footing from loans or share capital. Once identity of partners, confirmatio...