Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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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