Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
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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