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    <title>2025 (2) TMI 700 - ITAT DELHI</title>
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    <description>The ITAT DELHI held that the Assessing Officer (AO) and CIT(A) failed to properly examine the assessee&#039;s explanation regarding credit card payments, which were small and sourced from salary, borrowings, cash, and loan recoveries. The matter was remitted to the AO for detailed scrutiny of bank statements and salary records. Regarding the non-issuance of notice under section 143(2), it was held unnecessary for assessments under section 153A. Additions under section 292C based on seized documents were deleted as the AO did not sufficiently investigate or link the documents to undisclosed income, and the presumption under section 292C was rebutted by the assessee&#039;s denial. The additions made by the AO and upheld by CIT(A) were set aside.</description>
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      <title>2025 (2) TMI 700 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=766153</link>
      <description>The ITAT DELHI held that the Assessing Officer (AO) and CIT(A) failed to properly examine the assessee&#039;s explanation regarding credit card payments, which were small and sourced from salary, borrowings, cash, and loan recoveries. The matter was remitted to the AO for detailed scrutiny of bank statements and salary records. Regarding the non-issuance of notice under section 143(2), it was held unnecessary for assessments under section 153A. Additions under section 292C based on seized documents were deleted as the AO did not sufficiently investigate or link the documents to undisclosed income, and the presumption under section 292C was rebutted by the assessee&#039;s denial. The additions made by the AO and upheld by CIT(A) were set aside.</description>
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