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    <title>2026 (1) TMI 806 - ITAT DELHI</title>
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    <description>Reopening of assessment challenged on discrepancies between transaction value and circle rate of purchased immovable property; tribunal confirms that valuation adjustment provision applies to the seller only, and therefore any addition computed against the purchaser on that basis is unsustainable, resulting in deletion of that addition. Separate addition relating to unexplained loans was deleted where the purchaser produced confirmations, ITR acknowledgements, bank statements, audited financials of lenders and evidence of repayment within the same year, thereby satisfying the evidentiary requirement to establish identity and creditworthiness and discharging the onus for admitting loan credits. Both contested additions were removed.</description>
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    <pubDate>Wed, 26 Nov 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=785050</link>
      <description>Reopening of assessment challenged on discrepancies between transaction value and circle rate of purchased immovable property; tribunal confirms that valuation adjustment provision applies to the seller only, and therefore any addition computed against the purchaser on that basis is unsustainable, resulting in deletion of that addition. Separate addition relating to unexplained loans was deleted where the purchaser produced confirmations, ITR acknowledgements, bank statements, audited financials of lenders and evidence of repayment within the same year, thereby satisfying the evidentiary requirement to establish identity and creditworthiness and discharging the onus for admitting loan credits. Both contested additions were removed.</description>
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