Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
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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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