Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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ITAT adjudicated two key issues involving tax treatment of commercial transactions. First, regarding interest disallowance under section 36(1)(iii), the Tribunal held that loans advanced to third parties constituted genuine commercial transactions. Despite non-recovery of interest, the Tribunal found no evidence of fund diversion, ruling in favor of the assessee. Second, concerning melting charges, the Tribunal set aside the addition based on estimated melting gain, directing the Assessing Officer to delete the addition, respecting the assessee's maintained accounting records and following precedent from a prior assessment year. Both substantive issues were resolved in the assessee's favor, emphasizing commercial reasonableness and proper accounting practices.
ITAT adjudicated two key issues involving tax treatment of commercial transactions. First, regarding interest disallowance under section 36(1)(iii), the Tribunal held that loans advanced to third parties constituted genuine commercial transactions. Despite non-recovery of interest, the Tribunal found no evidence of fund diversion, ruling in favor of the assessee. Second, concerning melting charges, the Tribunal set aside the addition based on estimated melting gain, directing the Assessing Officer to delete the addition, respecting the assessee's maintained accounting records and following precedent from a prior assessment year. Both substantive issues were resolved in the assessee's favor, emphasizing commercial reasonableness and proper accounting practices.
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