Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
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.
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