https://www.taxtmi.com/caselaws?id=752293 ITAT Delhi upheld CIT(A)'s admission of additional evidence under Rule 46A(1)(c)(d), citing Delhi HC precedent in Virgin Securities case, finding evidence crucial for appeal disposal. Court deleted additions for unexplained receipts of Rs. 1.47 crore and purchases under Section 40A(3) after assessee produced sale deeds and confirmations validating transactions. Addition deletion due to calculation mistake was sustained as Revenue failed to prove error. Interest disallowance under Section 36(1)(iii) was reversed as Revenue couldn't establish direct linkage between borrowed funds and interest-free advances. Commission expense disallowance was deleted after AO found no fault in remand proceedings, with CIT(A)'s sustenance based on conjecture rather than facts. en-us Fri, 03 May 2024 00:00:00 +0530 Mon, 06 May 2024 16:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752293 ITAT Delhi upheld CIT(A)'s admission of additional evidence under Rule 46A(1)(c)(d), citing Delhi HC precedent in Virgin Securities case, finding evidence crucial for appeal disposal. Court deleted additions for unexplained receipts of Rs. 1.47 crore and purchases under Section 40A(3) after assessee produced sale deeds and confirmations validating transactions. Addition deletion due to calculation mistake was sustained as Revenue failed to prove error. Interest disallowance under Section 36(1)(iii) was reversed as Revenue couldn't establish direct linkage between borrowed funds and interest-free advances. Commission expense disallowance was deleted after AO found no fault in remand proceedings, with CIT(A)'s sustenance based on conjecture rather than facts. Case-Laws Income Tax Fri, 03 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752293