Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
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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