Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
For squared up loans, the surviving cash credit addition under section 68 was set aside for fresh adjudication because the assessee had now produced creditor confirmations and sought an effective opportunity, while the earlier record was found incomplete on identity, creditworthiness and genuineness. For three non-squared up loan creditors, the addition was deleted because the assessee had filed primary evidence such as returns, balance sheets, bank statements and confirmations, the creditors responded to notices, and the Revenue failed to rebut that evidence with cogent material; suspicion could not replace proof. The related interest disallowance was held to be consequential and was directed to be recomputed in line with the final treatment of the loan additions.
For squared up loans, the surviving cash credit addition under section 68 was set aside for fresh adjudication because the assessee had now produced creditor confirmations and sought an effective opportunity, while the earlier record was found incomplete on identity, creditworthiness and genuineness. For three non-squared up loan creditors, the addition was deleted because the assessee had filed primary evidence such as returns, balance sheets, bank statements and confirmations, the creditors responded to notices, and the Revenue failed to rebut that evidence with cogent material; suspicion could not replace proof. The related interest disallowance was held to be consequential and was directed to be recomputed in line with the final treatment of the loan additions.
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