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    <title>2019 (2) TMI 804 - ITAT DELHI</title>
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    <description>The ITAT upheld the CIT(A)&#039;s decision to delete an addition of Rs. 2,89,17,000 to the assessee&#039;s income for the assessment year 2012-13. The addition lacked merit as the receipts were offered in two financial years with proportionate TDS credits, and payments were received in different years, as per Section 199 of the Income Tax Act and Rule 37(BA)(3) of the IT Rules. The ITAT dismissed the Revenue&#039;s appeal, finding that the CIT(A) correctly considered the nature of the invoice and that the addition was unjustified based on the evidence presented.</description>
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      <title>2019 (2) TMI 804 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=375177</link>
      <description>The ITAT upheld the CIT(A)&#039;s decision to delete an addition of Rs. 2,89,17,000 to the assessee&#039;s income for the assessment year 2012-13. The addition lacked merit as the receipts were offered in two financial years with proportionate TDS credits, and payments were received in different years, as per Section 199 of the Income Tax Act and Rule 37(BA)(3) of the IT Rules. The ITAT dismissed the Revenue&#039;s appeal, finding that the CIT(A) correctly considered the nature of the invoice and that the addition was unjustified based on the evidence presented.</description>
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