Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
The ITAT upheld the assessed total income at Rs.1,10,70,33,060/- but partly allowed the assessee's appeal: it directed the AO to reduce an inadvertently offered additional income of Rs.1.14 crore (pertaining to AY 2010-11) from the assessment, and ordered deletion of a duplicate addition in AY 2010-11 which would have resulted in double taxation. The Tribunal affirmed that declared return income cannot be reduced. It allowed deduction of losses on forward commodity contracts as business expenditure under s.37(1) (held to be non-speculative hedging), and upheld the CIT(A)'s deletions disallowing revenue appeals against characterization of loan processing charges and foreign-currency hedging premium. Revenue's grounds were dismissed.
The ITAT upheld the assessed total income at Rs.1,10,70,33,060/- but partly allowed the assessee's appeal: it directed the AO to reduce an inadvertently offered additional income of Rs.1.14 crore (pertaining to AY 2010-11) from the assessment, and ordered deletion of a duplicate addition in AY 2010-11 which would have resulted in double taxation. The Tribunal affirmed that declared return income cannot be reduced. It allowed deduction of losses on forward commodity contracts as business expenditure under s.37(1) (held to be non-speculative hedging), and upheld the CIT(A)'s deletions disallowing revenue appeals against characterization of loan processing charges and foreign-currency hedging premium. Revenue's grounds were dismissed.
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