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    <title>2026 (3) TMI 681 - ITAT DELHI</title>
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    <description>A combined interpretation requires current year business income to be first set off against brought forward business losses before applying unabsorbed depreciation; the appellate adjustment in reverse order was corrected and reliance on change in shareholding was invalid where the enhancement notice procedure was not followed. Amounts written back that were previously disallowed when provisions were created, and capital creditors written back, do not become taxable under the deeming provision; therefore additions under the deeming provision on those sums were disallowed. The article concludes rectification of set off and removal of the impugned additions in favour of the assessee.</description>
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    <pubDate>Mon, 16 Feb 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=787926</link>
      <description>A combined interpretation requires current year business income to be first set off against brought forward business losses before applying unabsorbed depreciation; the appellate adjustment in reverse order was corrected and reliance on change in shareholding was invalid where the enhancement notice procedure was not followed. Amounts written back that were previously disallowed when provisions were created, and capital creditors written back, do not become taxable under the deeming provision; therefore additions under the deeming provision on those sums were disallowed. The article concludes rectification of set off and removal of the impugned additions in favour of the assessee.</description>
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      <pubDate>Mon, 16 Feb 2026 00:00:00 +0530</pubDate>
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