Extended limitation requires willful misstatement or suppression with intent to evade; mere misclassification does not sustain confiscation or penalty...
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Addition under section 68 concerning unsecured loans addressed the onus of proof regarding lender identity, creditworthiness and genuineness of transactions; the taxpayer discharged the primary onus by adducing credible evidence and fact-based findings supporting lender identity and creditworthiness, leading to deletion of the addition by the first appellate authority which the appellate body declined to disturb. Reliance on prior judicial precedents supporting the factual conclusions was noted, and the revenues grounds challenging the deletion were dismissed.
Addition under section 68 concerning unsecured loans addressed the onus of proof regarding lender identity, creditworthiness and genuineness of transactions; the taxpayer discharged the primary onus by adducing credible evidence and fact-based findings supporting lender identity and creditworthiness, leading to deletion of the addition by the first appellate authority which the appellate body declined to disturb. Reliance on prior judicial precedents supporting the factual conclusions was noted, and the revenues grounds challenging the deletion were dismissed.
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