Administrative fraud classification suspension does not halt independent criminal investigation or warrant-based searches into alleged economic offenc...
Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
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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