Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
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Addition u/s 68 - Bogus share capital and share premium received. The assessee failed to prove the identity and creditworthiness of the subscriber companies and the genuineness of the transactions. The assessee could not justify the huge premium charged nor establish the creditworthiness of the share applicants/shareholders. Most applicants lacked regular income sources or strong financials to justify the investment with huge premium. The assessee did not carry out any valuation to justify the premium charged. The transactions relating to share issuance were not genuine, and the creditworthiness of the creditors was not established. Based on judicial precedents and the CIT(A)'s findings that the applicants were shell companies, the ITAT upheld the CIT(A)'s order treating the addition u/s 68 as valid.
Addition u/s 68 - Bogus share capital and share premium received. The assessee failed to prove the identity and creditworthiness of the subscriber companies and the genuineness of the transactions. The assessee could not justify the huge premium charged nor establish the creditworthiness of the share applicants/shareholders. Most applicants lacked regular income sources or strong financials to justify the investment with huge premium. The assessee did not carry out any valuation to justify the premium charged. The transactions relating to share issuance were not genuine, and the creditworthiness of the creditors was not established. Based on judicial precedents and the CIT(A)'s findings that the applicants were shell companies, the ITAT upheld the CIT(A)'s order treating the addition u/s 68 as valid.
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