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    <title>2025 (6) TMI 1744 - ITAT DELHI</title>
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    <description>ITAT Delhi dismissed Revenue&#039;s appeal challenging deletion of protective additions made for alleged accommodation entries and unaccounted commission income. The court confirmed that while protective assessments are permissible under established SC precedent in Lalji Haridas case to protect Revenue interests, the specific facts showed substantive additions were already confirmed in hands of directors/related persons who were actual beneficiaries. Since appellants were found to be mere namelenders without independent taxable income, and corresponding substantive additions were upheld, CIT(A) correctly deleted the protective additions to avoid double taxation.</description>
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    <pubDate>Fri, 20 Dec 2024 00:00:00 +0530</pubDate>
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      <title>2025 (6) TMI 1744 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=773631</link>
      <description>ITAT Delhi dismissed Revenue&#039;s appeal challenging deletion of protective additions made for alleged accommodation entries and unaccounted commission income. The court confirmed that while protective assessments are permissible under established SC precedent in Lalji Haridas case to protect Revenue interests, the specific facts showed substantive additions were already confirmed in hands of directors/related persons who were actual beneficiaries. Since appellants were found to be mere namelenders without independent taxable income, and corresponding substantive additions were upheld, CIT(A) correctly deleted the protective additions to avoid double taxation.</description>
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      <pubDate>Fri, 20 Dec 2024 00:00:00 +0530</pubDate>
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