Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Interest income on Inter Corporate Deposits (ICD) and Fixed Deposits (FD) treated as income under "Profits & Gains of Business or Profession" instead of "Income from Other Sources" upheld. Assessee engaged in leasing and financing business as per Memorandum of Association (MOA). Non-registration as Non-Banking Finance Company (NBFC) not a valid reason for changing head of income. Rule of consistency demands consistent treatment when accepted as business income in preceding and succeeding years. Disallowance of amortized preliminary expenses set aside, directed to allow amortization consistent with treatment in other years. Appeal partly allowed.
Interest income on Inter Corporate Deposits (ICD) and Fixed Deposits (FD) treated as income under "Profits & Gains of Business or Profession" instead of "Income from Other Sources" upheld. Assessee engaged in leasing and financing business as per Memorandum of Association (MOA). Non-registration as Non-Banking Finance Company (NBFC) not a valid reason for changing head of income. Rule of consistency demands consistent treatment when accepted as business income in preceding and succeeding years. Disallowance of amortized preliminary expenses set aside, directed to allow amortization consistent with treatment in other years. Appeal partly allowed.
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