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...
The ITAT upheld the CIT(A)'s deletion of additions under section 68 concerning unexplained share capital and share premium credits, finding the assessee successfully demonstrated these were earlier credited funds transferred via journal entries among related parties, with no fresh funds introduced during the relevant year. Consequently, the revenue's appeal on this ground was dismissed. However, regarding advances shown under other liabilities, the CIT(A) accepted fresh evidence without remanding the matter to the AO for verification of identity, genuineness, and creditworthiness of the parties, violating procedural requirements. The ITAT agreed with the revenue that the issue required reconsideration and partly allowed the appeal for statistical purposes, mandating further examination of the advances' legitimacy.
The ITAT upheld the CIT(A)'s deletion of additions under section 68 concerning unexplained share capital and share premium credits, finding the assessee successfully demonstrated these were earlier credited funds transferred via journal entries among related parties, with no fresh funds introduced during the relevant year. Consequently, the revenue's appeal on this ground was dismissed. However, regarding advances shown under other liabilities, the CIT(A) accepted fresh evidence without remanding the matter to the AO for verification of identity, genuineness, and creditworthiness of the parties, violating procedural requirements. The ITAT agreed with the revenue that the issue required reconsideration and partly allowed the appeal for statistical purposes, mandating further examination of the advances' legitimacy.
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