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    <title>2024 (3) TMI 1148 - ITAT DELHI</title>
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    <description>ITAT Delhi dismissed the assessee&#039;s appeal challenging assessment u/s 143(3). The tribunal held that failure to receive notices due to changed email address without informing revenue authorities was not the AO&#039;s fault, as the assessee had accessed registered email until February 2020. Regarding disallowance of exceptional items worth Rs. 144.49 crores claimed as revenue expenditure, the tribunal ruled this represented income from granting 99-year lease rights to RFCL in exchange for equity shares, not deductible expenditure. The tribunal directed AO to avoid double taxation if the amount was offered to tax in subsequent years.</description>
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      <link>https://www.taxtmi.com/caselaws?id=750651</link>
      <description>ITAT Delhi dismissed the assessee&#039;s appeal challenging assessment u/s 143(3). The tribunal held that failure to receive notices due to changed email address without informing revenue authorities was not the AO&#039;s fault, as the assessee had accessed registered email until February 2020. Regarding disallowance of exceptional items worth Rs. 144.49 crores claimed as revenue expenditure, the tribunal ruled this represented income from granting 99-year lease rights to RFCL in exchange for equity shares, not deductible expenditure. The tribunal directed AO to avoid double taxation if the amount was offered to tax in subsequent years.</description>
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