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    <title>2025 (6) TMI 1217 - ITAT DELHI</title>
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    <description>ITAT Delhi dismissed Revenue&#039;s appeals in multiple grounds. Court held discount money offered to buyers was contractual arrangement, not on-money, lacking evidence of actual receipt. Transactions found on seized hard-disk belonged to different entities, not assessee. Alleged bogus purchases were sub-contractor transactions not recorded in assessee&#039;s books. Unsecured loans were genuine with proper documentation and lender confirmations. Ad hoc disallowances without verification were improper. Cash found during search was legitimately redeposited during demonetization. However, Court sustained addition for deferred payment scheme lacking proper documentation. Deemed dividend provisions under section 2(22)(e) were upheld for unsecured loans from group companies having reserves.</description>
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      <link>https://www.taxtmi.com/caselaws?id=773104</link>
      <description>ITAT Delhi dismissed Revenue&#039;s appeals in multiple grounds. Court held discount money offered to buyers was contractual arrangement, not on-money, lacking evidence of actual receipt. Transactions found on seized hard-disk belonged to different entities, not assessee. Alleged bogus purchases were sub-contractor transactions not recorded in assessee&#039;s books. Unsecured loans were genuine with proper documentation and lender confirmations. Ad hoc disallowances without verification were improper. Cash found during search was legitimately redeposited during demonetization. However, Court sustained addition for deferred payment scheme lacking proper documentation. Deemed dividend provisions under section 2(22)(e) were upheld for unsecured loans from group companies having reserves.</description>
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