Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Unsecured loans alleged to be accommodation entries require evaluation of lender identity, creditworthiness and transaction genuineness. Confirmations, bank statements, ledger accounts, receipt through banking channels, and repayment with interest support those requirements; generic third-party search information or allegations of entry providers do not, without contrary material, displace such evidence. Interest expenditure connected with a supported loan requires evidence of actual incurrence or payment, rather than presumption or estimation based merely on an alleged consequential liability.
Unsecured loans alleged to be accommodation entries require evaluation of lender identity, creditworthiness and transaction genuineness. Confirmations, bank statements, ledger accounts, receipt through banking channels, and repayment with interest support those requirements; generic third-party search information or allegations of entry providers do not, without contrary material, displace such evidence. Interest expenditure connected with a supported loan requires evidence of actual incurrence or payment, rather than presumption or estimation based merely on an alleged consequential liability.
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