Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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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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