Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
The Tribunal upheld deletion of section 68 additions for unsecured loans because the assessee produced confirmations, ledger accounts, income-tax returns, financial statements and bank statements showing identity, creditworthiness and genuineness, with receipts routed through banking channels and no rebuttal by the Revenue. It also accepted telescoping where the cash used for cheque-against-cash entries was linked to an already taxed on-money stream, so the related principal and interest additions did not survive. On disallowance of interest for diversion of borrowed funds, the Tribunal sustained only the reduced amount after finding no error in the appellate working of interest-free funds and advances.
The Tribunal upheld deletion of section 68 additions for unsecured loans because the assessee produced confirmations, ledger accounts, income-tax returns, financial statements and bank statements showing identity, creditworthiness and genuineness, with receipts routed through banking channels and no rebuttal by the Revenue. It also accepted telescoping where the cash used for cheque-against-cash entries was linked to an already taxed on-money stream, so the related principal and interest additions did not survive. On disallowance of interest for diversion of borrowed funds, the Tribunal sustained only the reduced amount after finding no error in the appellate working of interest-free funds and advances.
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