Genuineness of investment evidence determines LTCG entitlement; non specific regulatory reports cannot displace transaction specific documentary proof...
Import entitlement for repairs and after sales service extends to authorised service agents; provisional release allowed subject to bond and quantitat...
The ITAT held that an outstanding balance taken over under a Business Transfer Agreement in a slump sale could not be treated as an interest-free advance to a group company for making a deemed interest addition. It accepted that the amount was not an actual loan from borrowed funds but part of a commercially expedient business arrangement, and also relied on the Revenue's consistent acceptance of the same position in later years. The Tribunal further found that a larger notional disallowance was untenable where the actual interest debited in the year was minimal. The impugned addition was deleted and income was directed to be recomputed accordingly.
The ITAT held that an outstanding balance taken over under a Business Transfer Agreement in a slump sale could not be treated as an interest-free advance to a group company for making a deemed interest addition. It accepted that the amount was not an actual loan from borrowed funds but part of a commercially expedient business arrangement, and also relied on the Revenue's consistent acceptance of the same position in later years. The Tribunal further found that a larger notional disallowance was untenable where the actual interest debited in the year was minimal. The impugned addition was deleted and income was directed to be recomputed accordingly.
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