Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
For unsecured loans under section 68, the note states that the assessee can discharge the onus by producing lender confirmation, PAN, bank statements, salary records and a reply to notice under section 133(6), thereby showing identity, creditworthiness and genuineness of the transaction. On that footing, and because the Revenue produced no contrary material, the addition was said to be unsustainable. It also notes the legal position that, for periods before 01.04.2023, section 68 did not require explanation of the source of source in unsecured-loan cases. The described effect is deletion of the addition, with consequential treatment of MAT credit, interest and penalty initiation issues.
For unsecured loans under section 68, the note states that the assessee can discharge the onus by producing lender confirmation, PAN, bank statements, salary records and a reply to notice under section 133(6), thereby showing identity, creditworthiness and genuineness of the transaction. On that footing, and because the Revenue produced no contrary material, the addition was said to be unsustainable. It also notes the legal position that, for periods before 01.04.2023, section 68 did not require explanation of the source of source in unsecured-loan cases. The described effect is deletion of the addition, with consequential treatment of MAT credit, interest and penalty initiation issues.
Note: It is a system-generated summary and is for quick reference only.
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