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    <title>2025 (7) TMI 968 - ITAT DELHI</title>
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    <description>The ITAT Delhi upheld the validity of reassessment proceedings, rejecting the assessee&#039;s contention that statutory approval under section 153D was required before passing the assessment order. The tribunal held that section 153D applies only to assessments consequent to search operations, not to reopening cases for escaped income after search assessments were concluded. However, the tribunal ruled in favor of the assessee regarding commission income allegations, finding that the revenue&#039;s case of accommodation entries among group companies under common management lacked substantial evidence. The addition of 2% commission income based on market practice without tangible material was deleted as being founded on surmises and presumption.</description>
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    <pubDate>Wed, 09 Jul 2025 00:00:00 +0530</pubDate>
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      <title>2025 (7) TMI 968 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=774900</link>
      <description>The ITAT Delhi upheld the validity of reassessment proceedings, rejecting the assessee&#039;s contention that statutory approval under section 153D was required before passing the assessment order. The tribunal held that section 153D applies only to assessments consequent to search operations, not to reopening cases for escaped income after search assessments were concluded. However, the tribunal ruled in favor of the assessee regarding commission income allegations, finding that the revenue&#039;s case of accommodation entries among group companies under common management lacked substantial evidence. The addition of 2% commission income based on market practice without tangible material was deleted as being founded on surmises and presumption.</description>
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