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    <title>2025 (7) TMI 1804 - ITAT DELHI</title>
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    <description>The ITAT DELHI upheld the CIT(A)&#039;s order deleting additions related to client code modifications and commission earned, following precedent from a sister concern. It ruled against any disallowance under section 14A since no exempt income was earned during the year. Additions under section 2(22)(e) for deemed dividend were rejected as the credits arose from genuine business transactions outside the scope of the provision. Regarding losses on shares, the tribunal accepted the CIT(A)&#039;s factual finding that the assessee made profits on share transactions, contrary to the AO&#039;s assumption of loss, and upheld taxation of the profits. The Revenue failed to provide evidence to overturn the CIT(A)&#039;s conclusions, leading the ITAT to affirm the appellate order in favor of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=775736</link>
      <description>The ITAT DELHI upheld the CIT(A)&#039;s order deleting additions related to client code modifications and commission earned, following precedent from a sister concern. It ruled against any disallowance under section 14A since no exempt income was earned during the year. Additions under section 2(22)(e) for deemed dividend were rejected as the credits arose from genuine business transactions outside the scope of the provision. Regarding losses on shares, the tribunal accepted the CIT(A)&#039;s factual finding that the assessee made profits on share transactions, contrary to the AO&#039;s assumption of loss, and upheld taxation of the profits. The Revenue failed to provide evidence to overturn the CIT(A)&#039;s conclusions, leading the ITAT to affirm the appellate order in favor of the assessee.</description>
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