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...
ITAT held that beneficial ownership of funds introduced in a partnership firm supersedes strict legal ownership requirements. Despite capital being routed through partners' joint bank account, the tribunal recognized the firm's beneficial ownership based on audited financial statements. The AO's addition under Section 69 was deemed unsustainable, as the assessee successfully demonstrated the genuine source of capital through mutual fund redemptions and unsecured loans from related parties. The tribunal emphasized distinguishing between legal and beneficial ownership, particularly in partnership contexts, and allowed the assessee's appeal by deleting the unexplained investment addition.
ITAT held that beneficial ownership of funds introduced in a partnership firm supersedes strict legal ownership requirements. Despite capital being routed through partners' joint bank account, the tribunal recognized the firm's beneficial ownership based on audited financial statements. The AO's addition under Section 69 was deemed unsustainable, as the assessee successfully demonstrated the genuine source of capital through mutual fund redemptions and unsecured loans from related parties. The tribunal emphasized distinguishing between legal and beneficial ownership, particularly in partnership contexts, and allowed the assessee's appeal by deleting the unexplained investment addition.
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