Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Customs valuation and classification require comparable evidence and assessment of imported goods in their actual condition, invalidating related pena...
ITAT dismissed the Revenue's appeal and upheld the order of the CIT(A) deleting additions made u/ss 68 and 69C in assessment framed u/s 153A. ITAT held that unsecured loans received by Assessee X from various companies could not be treated as bogus merely on the basis of third-party statements recorded u/s 131(1A), which were subsequently retracted, especially in absence of any incriminating material seized during search. The excel sheet found on an employee's laptop was held not to be incriminating, as all entries were duly recorded in Assessee X's books and fully corroborated by bank statements, financials, confirmations, PAN and tax records of lenders. ITAT further held that, once loans are accepted as genuine, the related addition of 1% commission u/s 69C for alleged accommodation entries also fails. All grounds raised by the Revenue were therefore rejected.
ITAT dismissed the Revenue's appeal and upheld the order of the CIT(A) deleting additions made u/ss 68 and 69C in assessment framed u/s 153A. ITAT held that unsecured loans received by Assessee X from various companies could not be treated as bogus merely on the basis of third-party statements recorded u/s 131(1A), which were subsequently retracted, especially in absence of any incriminating material seized during search. The excel sheet found on an employee's laptop was held not to be incriminating, as all entries were duly recorded in Assessee X's books and fully corroborated by bank statements, financials, confirmations, PAN and tax records of lenders. ITAT further held that, once loans are accepted as genuine, the related addition of 1% commission u/s 69C for alleged accommodation entries also fails. All grounds raised by the Revenue were therefore rejected.
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