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The ITAT upheld the deletion of additions relating to contingent liabilities and bogus purchases, as the assessee furnished requisite party-wise details and confirmations during appellate and remand proceedings, which the AO verified and accepted. Regarding the loan processing fee, the Tribunal set aside the issue to the AO for fresh examination of the loan's purpose, directing that if the loan was for capital asset acquisition, the fee should be capitalized, but if for working capital, it should be allowed as a revenue expense. Similarly, the disallowance of interest under section 57 was set aside for reassessment, with the AO instructed to determine whether share investments were made from borrowings or own funds, providing the assessee an opportunity to present evidence. The Revenue's grounds were partly allowed for statistical purposes, with remand directions for detailed fact-finding.
The ITAT upheld the deletion of additions relating to contingent liabilities and bogus purchases, as the assessee furnished requisite party-wise details and confirmations during appellate and remand proceedings, which the AO verified and accepted. Regarding the loan processing fee, the Tribunal set aside the issue to the AO for fresh examination of the loan's purpose, directing that if the loan was for capital asset acquisition, the fee should be capitalized, but if for working capital, it should be allowed as a revenue expense. Similarly, the disallowance of interest under section 57 was set aside for reassessment, with the AO instructed to determine whether share investments were made from borrowings or own funds, providing the assessee an opportunity to present evidence. The Revenue's grounds were partly allowed for statistical purposes, with remand directions for detailed fact-finding.
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