Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Addition u/s 68 - unexplained cash credits - Onus to prove - CIT(A) deleted addition - The Tribunal found that the assessee failed to discharge its onus of proving the identity, creditworthiness, and genuineness of the transaction. - The ITAT held that, in view of such facts the observations of Ld. AO cannot be rejected at threshold, in absence of submission of requisite documents pertaining to the alleged creditor by the assessee having primary onus to satisfy the Ld. AO according to the provisions of section 68, who is supporting its contentions only by producing certain internal documents and bank statements. - Therefore, the addition made by the AO under section 68 was upheld.
Addition u/s 68 - unexplained cash credits - Onus to prove - CIT(A) deleted addition - The Tribunal found that the assessee failed to discharge its onus of proving the identity, creditworthiness, and genuineness of the transaction. - The ITAT held that, in view of such facts the observations of Ld. AO cannot be rejected at threshold, in absence of submission of requisite documents pertaining to the alleged creditor by the assessee having primary onus to satisfy the Ld. AO according to the provisions of section 68, who is supporting its contentions only by producing certain internal documents and bank statements. - Therefore, the addition made by the AO under section 68 was upheld.
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