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...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
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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