Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
ITAT adjudicated a tax dispute concerning interest income from a non-performing debt. The tribunal determined that no interest income could be recognized when the debtor was declared an NPA and undergoing insolvency proceedings. The key legal principle established was that taxation must be based on realistic income probability, not hypothetical earnings. The tribunal upheld the lower appellate authority's decision, rejecting the assessee's claim to recognize interest income on an accrual basis. Additionally, the tribunal denied TDS credit since no corresponding income was declared, citing precedent that TDS cannot be claimed without corresponding income recognition. The order effectively deleted the interest amount of Rs. 3,60,00,000/- and dismissed the assessee's grounds for TDS credit.
ITAT adjudicated a tax dispute concerning interest income from a non-performing debt. The tribunal determined that no interest income could be recognized when the debtor was declared an NPA and undergoing insolvency proceedings. The key legal principle established was that taxation must be based on realistic income probability, not hypothetical earnings. The tribunal upheld the lower appellate authority's decision, rejecting the assessee's claim to recognize interest income on an accrual basis. Additionally, the tribunal denied TDS credit since no corresponding income was declared, citing precedent that TDS cannot be claimed without corresponding income recognition. The order effectively deleted the interest amount of Rs. 3,60,00,000/- and dismissed the assessee's grounds for TDS credit.
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