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...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
The ITAT held that unsecured loan amounts received in A.Y. 2020-21 could not be added again under section 68 because the same sums were later forfeited and offered to tax as other income in A.Y. 2023-24. On the factual record, the assessee's computation of income, profit and loss account, and breakup of other income showed that the forfeited loan amounts from the two creditors had already been subjected to tax. Taxing them once more in the year of receipt would create double taxation, so the addition was unsustainable and was deleted.
The ITAT held that unsecured loan amounts received in A.Y. 2020-21 could not be added again under section 68 because the same sums were later forfeited and offered to tax as other income in A.Y. 2023-24. On the factual record, the assessee's computation of income, profit and loss account, and breakup of other income showed that the forfeited loan amounts from the two creditors had already been subjected to tax. Taxing them once more in the year of receipt would create double taxation, so the addition was unsustainable and was deleted.
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