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    <title>2026 (7) TMI 684 - ITAT DELHI</title>
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    <description>Protective addition for alleged accommodation entries, including related commission income, was held unsustainable because the substantive addition in the alleged recipient&#039;s hands had already been deleted on merits; once the foundation of the bogus transaction failed, the consequential commission addition also fell. Additions based on bank deposits were likewise deleted because, in completed assessments under section 153A, additions require incriminating material found in the search, and the bank material was not shown to have been seized. The Revenue&#039;s appeals failed, and the relief granted by the first appellate authority remained undisturbed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794798</link>
      <description>Protective addition for alleged accommodation entries, including related commission income, was held unsustainable because the substantive addition in the alleged recipient&#039;s hands had already been deleted on merits; once the foundation of the bogus transaction failed, the consequential commission addition also fell. Additions based on bank deposits were likewise deleted because, in completed assessments under section 153A, additions require incriminating material found in the search, and the bank material was not shown to have been seized. The Revenue&#039;s appeals failed, and the relief granted by the first appellate authority remained undisturbed.</description>
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