Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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ITAT held that interest on unsecured loans was correctly disallowed under section 36(1)(iii). The assessee failed to substantiate the genuineness and creditworthiness of loan transactions. Mere routing of interest through banking channels or TDS deduction does not prove loan legitimacy. The tribunal found no credible documentary evidence to establish the identity of lenders or loan authenticity. The assessee's inability to provide repayment details or demonstrate commercial substance of loans justified the disallowance of interest expenditure. The decision reinforces the principle that deduction of interest is contingent upon proving a genuine and subsisting business liability. Ultimately, the appeal was decided against the assessee, upholding the lower authorities' findings.
ITAT held that interest on unsecured loans was correctly disallowed under section 36(1)(iii). The assessee failed to substantiate the genuineness and creditworthiness of loan transactions. Mere routing of interest through banking channels or TDS deduction does not prove loan legitimacy. The tribunal found no credible documentary evidence to establish the identity of lenders or loan authenticity. The assessee's inability to provide repayment details or demonstrate commercial substance of loans justified the disallowance of interest expenditure. The decision reinforces the principle that deduction of interest is contingent upon proving a genuine and subsisting business liability. Ultimately, the appeal was decided against the assessee, upholding the lower authorities' findings.
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