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    <title>2026 (5) TMI 675 - ITAT DELHI</title>
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    <description>Reopening under sections 147 and 148 was held unsustainable where the additions forming the recorded reasons had already been deleted on merits, so the basis for escapement no longer survived. Deduction under section 35(2AB) for in-house R&amp;D expenditure was allowed because the prescribed authority had certified the eligible spend, and the Assessing Officer could not disregard that certification outside the statutory mechanism. Additions based on estimated manufacturing-expense disparity and alleged R&amp;D revenue were deleted because the estimates were unsupported by the audited results and rested on survey findings from another year. In later years, the interest disallowance fell with the underlying loan addition, one JV-related issue was remanded for fresh verification, and the unpressed debit-balance write-off ground was not adjudicated.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791473</link>
      <description>Reopening under sections 147 and 148 was held unsustainable where the additions forming the recorded reasons had already been deleted on merits, so the basis for escapement no longer survived. Deduction under section 35(2AB) for in-house R&amp;D expenditure was allowed because the prescribed authority had certified the eligible spend, and the Assessing Officer could not disregard that certification outside the statutory mechanism. Additions based on estimated manufacturing-expense disparity and alleged R&amp;D revenue were deleted because the estimates were unsupported by the audited results and rested on survey findings from another year. In later years, the interest disallowance fell with the underlying loan addition, one JV-related issue was remanded for fresh verification, and the unpressed debit-balance write-off ground was not adjudicated.</description>
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