Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
The ITAT Surat ruled on unexplained cash credit u/s 68, finding the assessee proved identity, creditworthiness, and genuineness of unsecured loan receipts. Repayment evidence via banking channels was accepted. Legal precedents like CIT Vs Ayachi Chandrashekhar Narsangji were cited to support no addition when loans were repaid in subsequent years. Cases like ACIT Vs Naresh Nemchand Shah and Rajhans Construction (P) Ltd. were referenced for similar views. The decision in CIT Vs. Amber Tradecorp (P) ltd. emphasized no addition u/s 68 if loans were repaid. Precedents like Rohini Builders and USHA STUD AGRICULTURAL FARM LTD. were cited to support the assessee's position. The addition of unsecured loans was disallowed, and the appeal by the assessee was allowed.
The ITAT Surat ruled on unexplained cash credit u/s 68, finding the assessee proved identity, creditworthiness, and genuineness of unsecured loan receipts. Repayment evidence via banking channels was accepted. Legal precedents like CIT Vs Ayachi Chandrashekhar Narsangji were cited to support no addition when loans were repaid in subsequent years. Cases like ACIT Vs Naresh Nemchand Shah and Rajhans Construction (P) Ltd. were referenced for similar views. The decision in CIT Vs. Amber Tradecorp (P) ltd. emphasized no addition u/s 68 if loans were repaid. Precedents like Rohini Builders and USHA STUD AGRICULTURAL FARM LTD. were cited to support the assessee's position. The addition of unsecured loans was disallowed, and the appeal by the assessee was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4784
Join Channel
TaxTMI 
