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    <title>2024 (9) TMI 1871 - ITAT DELHI</title>
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    <description>Where assessments for the impugned years were completed and unabated and no incriminating material specific to those years was found during search/requisition, additions or disallowances based on search proceedings cannot be sustained; applying the binding precedent that year specific seized material is required for reassessment, the Tribunal deleted such additions for the two years. The Assessing Officer&#039;s apportionment of extrapolated suppressed sales lacked a clear evidentiary link to the impugned years and was rejected; those additions were deleted. Disallowances premised on alleged impermissible payments were also unsustainable in the absence of year specific incriminating material and were deleted. Appeals by the assessee were allowed and Revenue&#039;s challenges to the deletions dismissed.</description>
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    <pubDate>Tue, 10 Sep 2024 00:00:00 +0530</pubDate>
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      <title>2024 (9) TMI 1871 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=466558</link>
      <description>Where assessments for the impugned years were completed and unabated and no incriminating material specific to those years was found during search/requisition, additions or disallowances based on search proceedings cannot be sustained; applying the binding precedent that year specific seized material is required for reassessment, the Tribunal deleted such additions for the two years. The Assessing Officer&#039;s apportionment of extrapolated suppressed sales lacked a clear evidentiary link to the impugned years and was rejected; those additions were deleted. Disallowances premised on alleged impermissible payments were also unsustainable in the absence of year specific incriminating material and were deleted. Appeals by the assessee were allowed and Revenue&#039;s challenges to the deletions dismissed.</description>
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      <pubDate>Tue, 10 Sep 2024 00:00:00 +0530</pubDate>
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