Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
