Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Appellate Tribunal held that when interest income was credited to PEL's account by original borrowers, TDS obligations u/ss 193/194A were already fulfilled. The appellant, who later acquired PEL's lending rights, was not required to deduct TDS again on the same interest payments. No lender-borrower relationship existed between appellant and PEL, making appellant not a "person responsible" for TDS under the Act. Payments exceeding principal value of ICDs/NCDs/Term Loans cannot be classified as 'interest' u/s 2(28A)/2(28B). ITAT deleted demand raised u/s 201(1)/201(1A), noting that income characterization can differ between recipient and payer. Appeal allowed.
Appellate Tribunal held that when interest income was credited to PEL's account by original borrowers, TDS obligations u/ss 193/194A were already fulfilled. The appellant, who later acquired PEL's lending rights, was not required to deduct TDS again on the same interest payments. No lender-borrower relationship existed between appellant and PEL, making appellant not a "person responsible" for TDS under the Act. Payments exceeding principal value of ICDs/NCDs/Term Loans cannot be classified as 'interest' u/s 2(28A)/2(28B). ITAT deleted demand raised u/s 201(1)/201(1A), noting that income characterization can differ between recipient and payer. Appeal allowed.
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