Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
In an unexplained cash credit dispute involving an alleged accommodation loan, the ITAT held that the assessee discharged the primary onus by producing confirmation, bank statements, income-tax records, balance sheet, loan agreement and the lender's NBFC certificate. As the transaction was routed through banking channels and repaid, and the AO neither rebutted the documents nor made an effective enquiry, the additions could not rest on suspicion or third-party information alone. The Tribunal also held that alleged non-payment of interest in a later year was irrelevant to the year under appeal. The additions under sections 68 and 69C were deleted.
In an unexplained cash credit dispute involving an alleged accommodation loan, the ITAT held that the assessee discharged the primary onus by producing confirmation, bank statements, income-tax records, balance sheet, loan agreement and the lender's NBFC certificate. As the transaction was routed through banking channels and repaid, and the AO neither rebutted the documents nor made an effective enquiry, the additions could not rest on suspicion or third-party information alone. The Tribunal also held that alleged non-payment of interest in a later year was irrelevant to the year under appeal. The additions under sections 68 and 69C were deleted.
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