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    <title>2026 (5) TMI 1005 - ITAT DELHI</title>
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    <description>In a search-linked tax regime, the special statutory post-search procedure prevails over the general assessment route, so the assessment for AY 2016-17 was held invalid and the AY 2022-23 order was quashed. CSR expenditure was treated as falling within the disallowance framework under Explanation 2 to section 37(1), but the matter was restored for fresh verification, including the alternative claim under section 80G. Additions for alleged over invoicing, bogus purchases, and excess stock were deleted because the books were not rejected, quantitative discrepancies were absent, and the record did not support ad hoc estimates. The cash addition was sustained as telescoped against business income to avoid double taxation.</description>
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