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Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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For unsecured loans, the notes state that before 1 April 2023, section 68 did not require an assessee to establish the source of a lender's funds, except for credits such as share application money, share capital or share premium. Based on remand reports accepting confirmations, creditworthiness and genuineness, the Tribunal treated the loans as genuine, deleted the section 68 additions and allowed related interest. For interest-free advances, where partners' capital and other non-interest-bearing funds exceeded advances to group concerns, no interest disallowance under section 36(1)(iii) was warranted. The related disallowances were deleted and all appeals were allowed.
For unsecured loans, the notes state that before 1 April 2023, section 68 did not require an assessee to establish the source of a lender's funds, except for credits such as share application money, share capital or share premium. Based on remand reports accepting confirmations, creditworthiness and genuineness, the Tribunal treated the loans as genuine, deleted the section 68 additions and allowed related interest. For interest-free advances, where partners' capital and other non-interest-bearing funds exceeded advances to group concerns, no interest disallowance under section 36(1)(iii) was warranted. The related disallowances were deleted and all appeals were allowed.
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