Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
The ITAT upheld the deletion of addition u/s 68 regarding the genuineness, creditworthiness, and transactions of loan creditors, relying on the orders of Ambe Tradecorp (P.) Ltd. [2022 (7) TMI 902 - Gujarat HC] and Sandip Kumar Gupta [2024 (7) TMI 1574 - ITAT Kolkata]. The loan amount was duly repaid during the assessment year, and the assessee was not the beneficial owner. The assessee provided evidence acknowledged by the CIT(A), ruling out contraventions of Section 68 regarding identity, creditworthiness, and banking channel transactions. The ITAT also upheld the CIT(A)'s decision on interest on the alleged unsecured loan, following the same principle laid down in the cited orders. The appeal was decided against the revenue.
The ITAT upheld the deletion of addition u/s 68 regarding the genuineness, creditworthiness, and transactions of loan creditors, relying on the orders of Ambe Tradecorp (P.) Ltd. [2022 (7) TMI 902 - Gujarat HC] and Sandip Kumar Gupta [2024 (7) TMI 1574 - ITAT Kolkata]. The loan amount was duly repaid during the assessment year, and the assessee was not the beneficial owner. The assessee provided evidence acknowledged by the CIT(A), ruling out contraventions of Section 68 regarding identity, creditworthiness, and banking channel transactions. The ITAT also upheld the CIT(A)'s decision on interest on the alleged unsecured loan, following the same principle laid down in the cited orders. The appeal was decided against the revenue.
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