Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
ITAT upheld deletion of disallowance of interest expenditure because the Assessing Officer failed to show any nexus between borrowed funds and non-business use, while the assessee had sufficient interest-free funds and used the borrowings for business purposes. It also sustained deletion of the section 68 addition on unsecured loans because bank statements, confirmations, income-tax records, TDS material and banking-channel transfers established genuineness. The Tribunal further rejected the purchase-difference addition, holding that purchases were recorded at actual cost and the variance from TCS figures arose from rebates, discounts and instances where TCS was not collected. The Revenue's appeal was dismissed in full.
ITAT upheld deletion of disallowance of interest expenditure because the Assessing Officer failed to show any nexus between borrowed funds and non-business use, while the assessee had sufficient interest-free funds and used the borrowings for business purposes. It also sustained deletion of the section 68 addition on unsecured loans because bank statements, confirmations, income-tax records, TDS material and banking-channel transfers established genuineness. The Tribunal further rejected the purchase-difference addition, holding that purchases were recorded at actual cost and the variance from TCS figures arose from rebates, discounts and instances where TCS was not collected. The Revenue's appeal was dismissed in full.
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