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 set aside the disallowance of freight charges, holding that mere suspicion without proof cannot justify rejecting expenses substantiated by audited accounts and vouchers. The disallowance under section 14A was deleted due to the AO's failure to record proper satisfaction before making additions. Additions based solely on Form 26AS mismatch were reversed as the assessee declared the amount in a subsequent year, preventing double taxation. The issue of carry forward losses was remitted to the AO for verification in accordance with law, with a direction to afford the assessee an opportunity of hearing. Disallowance of interest expenditure was also reversed, as the assessee had interest-free funds evidenced by loans and inventory financing, precluding blanket disallowance of finance costs. The appeal was allowed in part, with remand and deletion of certain additions.
The ITAT set aside the disallowance of freight charges, holding that mere suspicion without proof cannot justify rejecting expenses substantiated by audited accounts and vouchers. The disallowance under section 14A was deleted due to the AO's failure to record proper satisfaction before making additions. Additions based solely on Form 26AS mismatch were reversed as the assessee declared the amount in a subsequent year, preventing double taxation. The issue of carry forward losses was remitted to the AO for verification in accordance with law, with a direction to afford the assessee an opportunity of hearing. Disallowance of interest expenditure was also reversed, as the assessee had interest-free funds evidenced by loans and inventory financing, precluding blanket disallowance of finance costs. The appeal was allowed in part, with remand and deletion of certain additions.
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