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    <title>2025 (12) TMI 1821 - ITAT DELHI</title>
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    <description>In a limited-scrutiny assessment, the Assessing Officer cannot make additions on issues outside the selected scope unless the case is validly converted to complete scrutiny with the required prior approval under binding CBDT instructions. Additions on deemed dividend and unexplained money, made without such approval, were therefore unsustainable and were deleted. Once the jurisdictional defect was ative, the first appellate authority was not required to adjudicate the merits of those additions, because that issue became academic. The Revenue&#039;s challenge consequently failed, and the deletion of the additions was upheld.</description>
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    <pubDate>Wed, 10 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1821 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=468253</link>
      <description>In a limited-scrutiny assessment, the Assessing Officer cannot make additions on issues outside the selected scope unless the case is validly converted to complete scrutiny with the required prior approval under binding CBDT instructions. Additions on deemed dividend and unexplained money, made without such approval, were therefore unsustainable and were deleted. Once the jurisdictional defect was ative, the first appellate authority was not required to adjudicate the merits of those additions, because that issue became academic. The Revenue&#039;s challenge consequently failed, and the deletion of the additions was upheld.</description>
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      <pubDate>Wed, 10 Dec 2025 00:00:00 +0530</pubDate>
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