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    <title>2026 (9) TMI 1144 - ITAT DELHI</title>
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    <description>Differences between FCRA disclosures and income-tax return reporting cannot be treated as undisclosed income through a section 143(1) adjustment merely because the FCRA figure includes interest earned on invested foreign contributions. FCRA and income-tax disclosures serve different statutory purposes and require reconciliation based on substance rather than form. Where foreign contributions and related interest are separately declared, accounts are audited without qualification, the reporting approach has been accepted in other years, and supporting explanations are provided in rectification proceedings, a prima facie adjustment is unsustainable. The addition was deleted.</description>
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      <description>Differences between FCRA disclosures and income-tax return reporting cannot be treated as undisclosed income through a section 143(1) adjustment merely because the FCRA figure includes interest earned on invested foreign contributions. FCRA and income-tax disclosures serve different statutory purposes and require reconciliation based on substance rather than form. Where foreign contributions and related interest are separately declared, accounts are audited without qualification, the reporting approach has been accepted in other years, and supporting explanations are provided in rectification proceedings, a prima facie adjustment is unsustainable. The addition was deleted.</description>
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