Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
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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