Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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.
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