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    <title>2025 (1) TMI 258 - ITAT DELHI</title>
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    <description>Additions for alleged bogus purchases, bogus sales and presumed commission income were unsustainable where the assessment treated the transactions as ingenuine but still accepted the returned income and book results without rejecting the books or recomputing true income. The Tribunal found this approach internally inconsistent: if the transactions were genuinely considered bogus, the Revenue had to assess income on that basis rather than retain the declared results and add commission on the same transactions. The principle that one part of a transaction cannot be accepted for assessment while the corresponding part is rejected was applied. The additions were deleted and relief was granted to the assessee.</description>
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    <pubDate>Fri, 03 Jan 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=764196</link>
      <description>Additions for alleged bogus purchases, bogus sales and presumed commission income were unsustainable where the assessment treated the transactions as ingenuine but still accepted the returned income and book results without rejecting the books or recomputing true income. The Tribunal found this approach internally inconsistent: if the transactions were genuinely considered bogus, the Revenue had to assess income on that basis rather than retain the declared results and add commission on the same transactions. The principle that one part of a transaction cannot be accepted for assessment while the corresponding part is rejected was applied. The additions were deleted and relief was granted to the assessee.</description>
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