Blocked input tax credit for resort construction remains unavailable; interest follows actual utilisation, while delayed payment attracts statutory pe...
Duplicate PAN allocation requires record verification and deactivation reasons before assessment-related transactions can be attributed to an assessee...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required...
The ITAT held that alleged documents of bank account with HSBC London were genuine as the assessee accepted and revised the return. Absence of incriminating material in search operation supported revenue's actions. Indo-UK DTAA Article 23(3) not applicable as source of deposits not established. AO's reference to FT&TR for info from UK valid. Accrued interest additions not sustainable due to lack of evidence beyond sourced statement. Penalty u/s 271(1)(c) not justified as no misreporting found. Increased penalty by CIT(A) also deleted. Other penalties on interest income deleted. Addition based on loose sheets dismissed as lacking evidentiary value. All grounds raised by assessee allowed.
The ITAT held that alleged documents of bank account with HSBC London were genuine as the assessee accepted and revised the return. Absence of incriminating material in search operation supported revenue's actions. Indo-UK DTAA Article 23(3) not applicable as source of deposits not established. AO's reference to FT&TR for info from UK valid. Accrued interest additions not sustainable due to lack of evidence beyond sourced statement. Penalty u/s 271(1)(c) not justified as no misreporting found. Increased penalty by CIT(A) also deleted. Other penalties on interest income deleted. Addition based on loose sheets dismissed as lacking evidentiary value. All grounds raised by assessee allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
