Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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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