Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Assessee successfully contested disallowances: the Tribunal found proportionate interest disallowance under section 36(1)(iii) unjustified because loans and advances were funded from the assessee's own interest-free funds and repayments demonstrated genuineness; reimbursement payments for staff training to Mahindra & Mahindra Ltd. did not attract TDS under section 194C and so section 40(a)(ia) disallowance was deleted; discrepancies between income in the return and Form 26AS were attributable to legitimate business adjustments and the assessee explained RTO reimbursements, so additions and the section 40A(3) cash expenditure disallowance were deleted. The appeal was allowed in entirety.
Assessee successfully contested disallowances: the Tribunal found proportionate interest disallowance under section 36(1)(iii) unjustified because loans and advances were funded from the assessee's own interest-free funds and repayments demonstrated genuineness; reimbursement payments for staff training to Mahindra & Mahindra Ltd. did not attract TDS under section 194C and so section 40(a)(ia) disallowance was deleted; discrepancies between income in the return and Form 26AS were attributable to legitimate business adjustments and the assessee explained RTO reimbursements, so additions and the section 40A(3) cash expenditure disallowance were deleted. The appeal was allowed in entirety.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
