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    <title>2026 (2) TMI 1135 - ITAT DELHI</title>
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    <description>Beneficial ownership governs taxability of sale proceeds: where a GPA-holder/vendee received consideration, took possession and acted as beneficial owner, consequent capital gains did not arise in the original vendor; deletion of short-term capital gains addition. Comparative turnover and proportional fuel expenses supported rejection of unexplained expenditure addition under the unexplained expenses test; deletion of fuel-related addition. Bonus payments documented and within statutory limits supported deletion of cash-bonus addition. Disallowance for non-deduction of TDS was deleted for bank interest (TDS-exempt) and allowed to be deleted for NBFC interest subject to verification that recipients disclosed corresponding income.</description>
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      <link>https://www.taxtmi.com/caselaws?id=786987</link>
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