Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
