Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Reassessment based on Investigation Wing information may rest on tangible material where it specifically links alleged accommodation entries to the taxpayer's loan transaction, creating a live nexus and demonstrating independent application of mind rather than borrowed satisfaction. For an unsecured-loan credit, confirmation, PAN, tax return, audited financial statements, bank records, interest payments with tax deduction, and repayment can discharge the taxpayer's burden. Third-party investigation material alone does not displace this evidence without proof that the taxpayer paid cash for the loan or that the lender's funds belonged to the taxpayer. The reassessment was sustained, while the cash-credit addition was deleted.
Reassessment based on Investigation Wing information may rest on tangible material where it specifically links alleged accommodation entries to the taxpayer's loan transaction, creating a live nexus and demonstrating independent application of mind rather than borrowed satisfaction. For an unsecured-loan credit, confirmation, PAN, tax return, audited financial statements, bank records, interest payments with tax deduction, and repayment can discharge the taxpayer's burden. Third-party investigation material alone does not displace this evidence without proof that the taxpayer paid cash for the loan or that the lender's funds belonged to the taxpayer. The reassessment was sustained, while the cash-credit addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
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