Tax authority's substitution of projected figures with actuals overturned; original acquisition valuation upheld; transfer pricing issues remitted for...
Beneficial owner held liable for differential customs duty; royalties added under Rule 10(1)(c); confiscation, penalties under s.111(m), s.114A, s.112...
HC allowed the appeal of the assessee, holding that unsecured loan credited in AY 2014-15 was genuine and not exigible to addition under section 68. The Court found the identity and creditworthiness of the creditor established by bank records and statements recorded under survey and section 133(6); repayments (with interest) through banking channels in the subsequent year corroborated genuineness. The revenue's challenge to the creditor's own source of funds ('source of the source') was rejected as immaterial for that assessment year (pre-Finance Act 2022 amendment). The HC upheld the ITAT/CIT(A) conclusions on merits and rejected the revenue's reliance on assessment provisions under section 153A.
HC allowed the appeal of the assessee, holding that unsecured loan credited in AY 2014-15 was genuine and not exigible to addition under section 68. The Court found the identity and creditworthiness of the creditor established by bank records and statements recorded under survey and section 133(6); repayments (with interest) through banking channels in the subsequent year corroborated genuineness. The revenue's challenge to the creditor's own source of funds ('source of the source') was rejected as immaterial for that assessment year (pre-Finance Act 2022 amendment). The HC upheld the ITAT/CIT(A) conclusions on merits and rejected the revenue's reliance on assessment provisions under section 153A.
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