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, 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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