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    <title>2024 (4) TMI 264 - ITAT DELHI</title>
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    <description>The ITAT Delhi dismissed the Revenue&#039;s appeals against the assessee company. The tribunal upheld CIT(A)&#039;s deletion of additions made under sections 69A and 69B. Regarding loyalty incentive income, the tribunal found the assessee had properly recognized the income in its books per accounting standards and agreements with suppliers. For unexplained investment and stock undervaluation additions, the tribunal noted these were based on a seized document showing 44.82% valuation difference, which was prepared for strategic presentation to investors, not actual business operations. The MD&#039;s statement during search was given under stress and later clarified. The tribunal found no merit in Revenue&#039;s grounds, confirming CIT(A)&#039;s decision to delete all additions.</description>
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    <pubDate>Thu, 04 Apr 2024 00:00:00 +0530</pubDate>
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      <title>2024 (4) TMI 264 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=751083</link>
      <description>The ITAT Delhi dismissed the Revenue&#039;s appeals against the assessee company. The tribunal upheld CIT(A)&#039;s deletion of additions made under sections 69A and 69B. Regarding loyalty incentive income, the tribunal found the assessee had properly recognized the income in its books per accounting standards and agreements with suppliers. For unexplained investment and stock undervaluation additions, the tribunal noted these were based on a seized document showing 44.82% valuation difference, which was prepared for strategic presentation to investors, not actual business operations. The MD&#039;s statement during search was given under stress and later clarified. The tribunal found no merit in Revenue&#039;s grounds, confirming CIT(A)&#039;s decision to delete all additions.</description>
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