Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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Addition treated as unexplained cash credit on an unsecured loan was deleted because the lender's identity, creditworthiness based on its financials, and the genuineness of the loan transaction from an NBFC had already been accepted on identical facts in a coordinate Bench decision. The Tribunal held that the Commissioner (Appeals) had sustained the addition mainly by relying on an order in a group concern's case involving the same lender, but that foundation no longer survived after the earlier order was reversed. Applying the same reasoning, the loan from M/s Sundram Consultants Pvt. Ltd. was not liable to be assessed as unexplained cash credit.
Addition treated as unexplained cash credit on an unsecured loan was deleted because the lender's identity, creditworthiness based on its financials, and the genuineness of the loan transaction from an NBFC had already been accepted on identical facts in a coordinate Bench decision. The Tribunal held that the Commissioner (Appeals) had sustained the addition mainly by relying on an order in a group concern's case involving the same lender, but that foundation no longer survived after the earlier order was reversed. Applying the same reasoning, the loan from M/s Sundram Consultants Pvt. Ltd. was not liable to be assessed as unexplained cash credit.
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