https://www.taxtmi.com/caselaws?id=755131 Delhi HC upheld ITAT's deletion of additions under Section 153A for assessment years 2012-13 to 2015-16. The assessee had a profit-sharing agreement with non-resident entity CMF for currency paper supply services to RBI, which terminated on 31.12.2012. Revenue failed to establish incriminating material linking foreign entity payments to the original CMF agreement. The agreement was already known to Revenue and commissions were disclosed in ITR. Court applied settled law that additions cannot be sustained without incriminating material for relevant assessment years. en-us Wed, 03 Jul 2024 00:00:00 +0530 Tue, 18 Mar 2025 16:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755131 Delhi HC upheld ITAT's deletion of additions under Section 153A for assessment years 2012-13 to 2015-16. The assessee had a profit-sharing agreement with non-resident entity CMF for currency paper supply services to RBI, which terminated on 31.12.2012. Revenue failed to establish incriminating material linking foreign entity payments to the original CMF agreement. The agreement was already known to Revenue and commissions were disclosed in ITR. Court applied settled law that additions cannot be sustained without incriminating material for relevant assessment years. Case-Laws Income Tax Wed, 03 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755131