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i. Assessee has to substantiate the benefit and linkage between the amount disclosed by him as total income as undisclosed income and telescoping of such undisclosed income with the amount of addition deleted by the learned CIT - A of opening balance.

ii. There is no centralized record of the balance available with the assessee as an opening balance and therefore the benefit given by the learned CIT - A of telescoping by looking at the fund flow statement is incorrect.

 v.    Statement recorded under section 132 (4) of the
       staff,    the   director       of        the     company             and
       investigation/examination           of    the     details       during

assessment proceedings categorically shown that the above sum is standing as opening balance in the seized documents as on 3/10/2020.

vi. On the issue of telescoping, honourable Supreme Court in 66 ITR 722 has categorically held that telescoping is a question of fact. Therefore, it is for the revenue to prove that the fund flow statement shown by the assessee is factually incorrect.

vii. Honourable Gujarat High Court in Aliasgar Anvarali Varteji [2018] 96 taxmann.com 231 (Gujarat) has categorically held that when the assessee has offered unaccounted income, its capitalization or telescoping assessee deserves. Of course, it is for revenue to show that the telescoping is not available because amount of income earned by the assessee have already been invested in other assets. Such fact is not demonstrated before us. Honourable Bombay High Court also in case of 61 Page | 29 ITA No. 3110 & 2547/Mum/2023 GNP Consultancy and Solutions Private Limited; A.Y. 21-22 taxmann.com 357 has also categorically held that when the income has already been taxed, its subsequent withdrawal cannot be taxed once again.

viii. Thus, in absence of any other adverse fact pointed out by the learned assessing officer, we do not find any infirmity in the order of the learned CIT - A in granting the benefit of telescoping.

ix. Thus, taking into consideration all the factors of disclosure made by the assessee for which telescoping has been granted, fund flow statement of additional income offered of ₹ 27.74 crores, consistent statement of director, staff, and submissions before the investigation Wing and the assessing officer, clearly establishes that the addition of ₹ 828,903/- is correctly deleted.