Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
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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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