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    <title>2026 (1) TMI 448 - ITAT DELHI</title>
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    <description>The dominant issue was whether an addition under s.69C for alleged unexplained expenditure linked to import transactions could be sustained without verifying NMS data and the recording of such imports in the books. The Tribunal held that where imports and related financial transactions were carried out using the PAN of a related concern, the decisive factual inquiry is whether those imports and payments, irrespective of PAN used, were already reflected in the assessee&#039;s audited accounts; if so, s.69C cannot be invoked. As this verification was not conclusively undertaken, the order deleting the addition was set aside on this issue and the matter was remitted to the AO for fresh verification, with a direction that no addition be made if the transactions are duly recorded.</description>
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      <title>2026 (1) TMI 448 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=784692</link>
      <description>The dominant issue was whether an addition under s.69C for alleged unexplained expenditure linked to import transactions could be sustained without verifying NMS data and the recording of such imports in the books. The Tribunal held that where imports and related financial transactions were carried out using the PAN of a related concern, the decisive factual inquiry is whether those imports and payments, irrespective of PAN used, were already reflected in the assessee&#039;s audited accounts; if so, s.69C cannot be invoked. As this verification was not conclusively undertaken, the order deleting the addition was set aside on this issue and the matter was remitted to the AO for fresh verification, with a direction that no addition be made if the transactions are duly recorded.</description>
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      <pubDate>Thu, 27 Nov 2025 00:00:00 +0530</pubDate>
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