Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
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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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