Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Unsecured loans received by assessee were supported by documentary evidence proving identity, genuineness, and creditworthiness of lenders. No contrary material brought by Revenue to doubt transactions. Hence, no addition u/s 68 was warranted and corresponding disallowance of interest u/s 69C was rightly deleted. Assessee did not earn any exempt income, only gains from investments. Section 14A disallowance applies when exempt income is received/receivable. As no exempt income was earned, disallowance u/s 14A read with Rule 8D was correctly deleted by CIT(A), even considering prospective amendment. Order in favor of assessee upheld.
Unsecured loans received by assessee were supported by documentary evidence proving identity, genuineness, and creditworthiness of lenders. No contrary material brought by Revenue to doubt transactions. Hence, no addition u/s 68 was warranted and corresponding disallowance of interest u/s 69C was rightly deleted. Assessee did not earn any exempt income, only gains from investments. Section 14A disallowance applies when exempt income is received/receivable. As no exempt income was earned, disallowance u/s 14A read with Rule 8D was correctly deleted by CIT(A), even considering prospective amendment. Order in favor of assessee upheld.
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