Anti-profiteering obligations survive business demerger, complaint withdrawal, and customized supply arrangements where rate-reduction benefits are no...
Road restoration charges constitute taxable services when requested for commercial pipeline activity, requiring reverse-charge GST from the business r...
Interest on delayed release of requisitioned cash includes statutory pre-assessment interest and restitutionary compensation for unlawful post-assessm...
Incomplete inventory records justify rejecting accounts, while profit estimation requires relevant comparable material and interest falls under other ...
Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
U/s 68, the assessee provided relevant details to explain the nature and source of unsecured loans, as well as the interest paid thereon, discharging the primary onus. Once the assessee fulfills this onus, the Assessing Officer (AO) must conduct necessary inquiries and record satisfaction before making any addition. The AO should have exercised powers u/s 133(6) or contacted the concerned AOs of the alleged parties, as their PAN and addresses were available. Following the Supreme Court's decision in Orissa Corpn. and the Tribunal's own decision, the assessee successfully explained the loans' nature, source, and creditors' identity and creditworthiness, proving the transactions' genuineness. Therefore, the CIT(A)'s deletion of the addition u/s 68 and interest disallowance was upheld, dismissing the Revenue's appeal.
U/s 68, the assessee provided relevant details to explain the nature and source of unsecured loans, as well as the interest paid thereon, discharging the primary onus. Once the assessee fulfills this onus, the Assessing Officer (AO) must conduct necessary inquiries and record satisfaction before making any addition. The AO should have exercised powers u/s 133(6) or contacted the concerned AOs of the alleged parties, as their PAN and addresses were available. Following the Supreme Court's decision in Orissa Corpn. and the Tribunal's own decision, the assessee successfully explained the loans' nature, source, and creditors' identity and creditworthiness, proving the transactions' genuineness. Therefore, the CIT(A)'s deletion of the addition u/s 68 and interest disallowance was upheld, dismissing the Revenue's appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
