Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT allowed the assessee's appeal, holding that the entire unsecured loan was utilized for business purposes with commercial expediency. The tribunal found no evidence of personal or capital usage of loan funds. The AO's disallowance of interest was deemed speculative, particularly when TDS was duly deducted. The tribunal concluded that the addition under Section 36(1)(iii) should be deleted, recognizing the loan's exclusive business application and the assessee's improved buying capacity leading to better gross profit margins.
ITAT allowed the assessee's appeal, holding that the entire unsecured loan was utilized for business purposes with commercial expediency. The tribunal found no evidence of personal or capital usage of loan funds. The AO's disallowance of interest was deemed speculative, particularly when TDS was duly deducted. The tribunal concluded that the addition under Section 36(1)(iii) should be deleted, recognizing the loan's exclusive business application and the assessee's improved buying capacity leading to better gross profit margins.
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