Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
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...
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The ITAT upheld the CIT(A)'s deletion of additions under section 68 relating to unsecured loans, finding the assessee satisfactorily proved the identity and creditworthiness of lenders and genuineness of transactions, supported by banking channel evidence and legal precedents. The tribunal confirmed that denial of cross-examination rendered the AO's additions unsustainable. Consequently, disallowance of interest on such loans and alleged commission payments were also deleted. The reassessment order under section 147 was quashed as the AO exceeded jurisdiction by making additions beyond the reasons recorded. Additions based on uncorroborated WhatsApp chats were deleted, adhering to principles against relying on non-speaking documents without corroborative evidence. The CIT(A)'s confirmation of disallowance of education and health cess expenses under section 40(a)(ii) and disallowance of delayed PF and ESI contributions under section 36(1)(va) was affirmed, following Supreme Court rulings. All revenue appeals were dismissed.
The ITAT upheld the CIT(A)'s deletion of additions under section 68 relating to unsecured loans, finding the assessee satisfactorily proved the identity and creditworthiness of lenders and genuineness of transactions, supported by banking channel evidence and legal precedents. The tribunal confirmed that denial of cross-examination rendered the AO's additions unsustainable. Consequently, disallowance of interest on such loans and alleged commission payments were also deleted. The reassessment order under section 147 was quashed as the AO exceeded jurisdiction by making additions beyond the reasons recorded. Additions based on uncorroborated WhatsApp chats were deleted, adhering to principles against relying on non-speaking documents without corroborative evidence. The CIT(A)'s confirmation of disallowance of education and health cess expenses under section 40(a)(ii) and disallowance of delayed PF and ESI contributions under section 36(1)(va) was affirmed, following Supreme Court rulings. All revenue appeals were dismissed.
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