Deductibility for charitable donations affirmed where payments to approved relief funds, even if CSR-driven, qualify under the donation deduction sche...
Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
Section 68 was largely satisfied where the assessee produced the lender's registration, PAN, bank statements, debenture documents, confirmation and source-of-source material; nil income alone did not negate creditworthiness, so only limited third-party verification under section 133(6) was left open if the Assessing Officer still needed the lender's accounts. Interest disallowance under section 40A(2)(b) failed because the lender was only a creditor, not shown to be a covered related concern, and no basis existed for adopting 6% as a reasonable rate. Proportionate interest disallowance under section 36(1)(iii) was deleted since the borrowing was for working capital, not capital asset acquisition. A flat 10% ad hoc expense disallowance was set aside for fresh verification. CSR disallowance was upheld, and TDS credit was directed to be verified.
Section 68 was largely satisfied where the assessee produced the lender's registration, PAN, bank statements, debenture documents, confirmation and source-of-source material; nil income alone did not negate creditworthiness, so only limited third-party verification under section 133(6) was left open if the Assessing Officer still needed the lender's accounts. Interest disallowance under section 40A(2)(b) failed because the lender was only a creditor, not shown to be a covered related concern, and no basis existed for adopting 6% as a reasonable rate. Proportionate interest disallowance under section 36(1)(iii) was deleted since the borrowing was for working capital, not capital asset acquisition. A flat 10% ad hoc expense disallowance was set aside for fresh verification. CSR disallowance was upheld, and TDS credit was directed to be verified.
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