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    <title>2025 (12) TMI 652 - ITAT DELHI</title>
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    <description>ITAT Delhi allowed the assessee&#039;s appeal. It held that the disputed sums received from the purchaser as advances under duly executed agreements for sale of farmhouses, with TDS deducted u/s 194I, constituted genuine advance receipts for transfer of immovable property and could not be taxed as unexplained cash credits u/s 68. The Tribunal found the purchaser&#039;s creditworthiness established and rejected the AO&#039;s characterization of the receipts as unexplained. Further, additions based on documents seized from a third person were deleted, as the AO failed to comply with the mandatory procedure and approvals required under Explanation 2 to section 148 for using third-party material against the assessee.</description>
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    <pubDate>Thu, 27 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 652 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=783112</link>
      <description>ITAT Delhi allowed the assessee&#039;s appeal. It held that the disputed sums received from the purchaser as advances under duly executed agreements for sale of farmhouses, with TDS deducted u/s 194I, constituted genuine advance receipts for transfer of immovable property and could not be taxed as unexplained cash credits u/s 68. The Tribunal found the purchaser&#039;s creditworthiness established and rejected the AO&#039;s characterization of the receipts as unexplained. Further, additions based on documents seized from a third person were deleted, as the AO failed to comply with the mandatory procedure and approvals required under Explanation 2 to section 148 for using third-party material against the assessee.</description>
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      <pubDate>Thu, 27 Nov 2025 00:00:00 +0530</pubDate>
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