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    <title>2024 (2) TMI 454 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=449303</link>
    <description>The ITAT Delhi dismissed the revenue&#039;s appeal regarding protective addition for unexplained credit entries in the assessee company&#039;s bank account. The tribunal held that the assessee was merely a conduit company operated to provide accommodation entries to beneficiaries in exchange for commission. Since funds were immediately transferred to identified beneficiaries after receipt, the credits could not be treated as unexplained in the assessee&#039;s hands. The arrangement was part of the modus operandi for routing unaccounted income. The CIT(A)&#039;s deletion of the protective addition was upheld, as substantive additions should be made against the actual beneficiaries rather than the conduit company.</description>
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    <pubDate>Tue, 06 Feb 2024 00:00:00 +0530</pubDate>
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      <title>2024 (2) TMI 454 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=449303</link>
      <description>The ITAT Delhi dismissed the revenue&#039;s appeal regarding protective addition for unexplained credit entries in the assessee company&#039;s bank account. The tribunal held that the assessee was merely a conduit company operated to provide accommodation entries to beneficiaries in exchange for commission. Since funds were immediately transferred to identified beneficiaries after receipt, the credits could not be treated as unexplained in the assessee&#039;s hands. The arrangement was part of the modus operandi for routing unaccounted income. The CIT(A)&#039;s deletion of the protective addition was upheld, as substantive additions should be made against the actual beneficiaries rather than the conduit company.</description>
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      <pubDate>Tue, 06 Feb 2024 00:00:00 +0530</pubDate>
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