Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Section 68 addition deleted - Assessee discharged onus to explain identity, creditworthiness of loan creditors and genuineness of transactions by providing voluminous evidence. Loans received were repaid during the year or subsequent year. Non-payment of interest alone cannot justify addition u/s 68. Section 14A disallowance deleted - Investments made from own funds and non-interest borrowings, following Supreme Court and High Court precedents. Interest disallowance on advances deleted - Advances given from own funds and non-interest borrowings, relying on High Court judgment. Write-off of advance on project abandonment allowed as business expenditure based on High Court decision. Revenue appeal dismissed by ITAT.
Section 68 addition deleted - Assessee discharged onus to explain identity, creditworthiness of loan creditors and genuineness of transactions by providing voluminous evidence. Loans received were repaid during the year or subsequent year. Non-payment of interest alone cannot justify addition u/s 68. Section 14A disallowance deleted - Investments made from own funds and non-interest borrowings, following Supreme Court and High Court precedents. Interest disallowance on advances deleted - Advances given from own funds and non-interest borrowings, relying on High Court judgment. Write-off of advance on project abandonment allowed as business expenditure based on High Court decision. Revenue appeal dismissed by ITAT.
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