ITAT Delhi Deletes ₹15.23 Cr Protective Addition to Prevent Double Taxation

DCIT Vs Surya Vanijya P. Ltd (ITAT Delhi)

Income Tax Appellate Tribunal (ITAT), Delhi Bench, in its order pronounced on February 7, 2025, dismissed an appeal by the Income Tax Department while simultaneously dismissing an appeal by Surya Vanijya P. Ltd. The Tribunal upheld the Commissioner of Income Tax (Appeals) [CIT(A)] decision to delete a protective addition of ₹15.23 crore made by the Assessing Officer (AO) but confirmed the addition of ₹38.07 lakh on account of unexplained commission expenditure.

The case pertains to Assessment Year 2014-15 and stems from a search

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