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...
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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