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Use of a company's disclosed income to purchase jewellery on its behalf does not, without more, constitute acceptance by its managing director of a cash loan or deposit. Storage of company jewellery at the managing director's residence or in his locker for safekeeping does not alter that character. Characterising the arrangement as a cash loan or deposit on assumptions, presumptions or surmise renders the related penalty unsustainable; the penalty was deleted.
Use of a company's disclosed income to purchase jewellery on its behalf does not, without more, constitute acceptance by its managing director of a cash loan or deposit. Storage of company jewellery at the managing director's residence or in his locker for safekeeping does not alter that character. Characterising the arrangement as a cash loan or deposit on assumptions, presumptions or surmise renders the related penalty unsustainable; the penalty was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
