<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>2025 (2) TMI 1921 - ITAT KOLKATA</title>
    <link>https://www.taxtmi.com/caselaws?id=468845</link>
    <description>Section 68 additions require corroborated evidence of unexplained credits; share-sale proceeds were held unsustainable where the assessee produced prior acquisition records, banking-channel transfers and responsive purchasers, while general entry-operator statements without cross-examination were insufficient. In unsecured-loan cases, confirmations, tax returns, audited statements, bank records and repayment supported genuineness, so the section 68 addition and connected interest and commission disallowances could not stand. For section 14A, where own funds exceeded investments, a presumption arose that the investments came from those funds, and proportionate interest disallowance was not warranted. The discussion also notes that, on the share transaction, only a limited profit-element approach could survive.</description>
    <language>en-us</language>
    <pubDate>Tue, 11 Feb 2025 00:00:00 +0530</pubDate>
    <lastBuildDate>Fri, 22 May 2026 12:48:21 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=903346" rel="self" type="application/rss+xml"/>
    <item>
      <title>2025 (2) TMI 1921 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=468845</link>
      <description>Section 68 additions require corroborated evidence of unexplained credits; share-sale proceeds were held unsustainable where the assessee produced prior acquisition records, banking-channel transfers and responsive purchasers, while general entry-operator statements without cross-examination were insufficient. In unsecured-loan cases, confirmations, tax returns, audited statements, bank records and repayment supported genuineness, so the section 68 addition and connected interest and commission disallowances could not stand. For section 14A, where own funds exceeded investments, a presumption arose that the investments came from those funds, and proportionate interest disallowance was not warranted. The discussion also notes that, on the share transaction, only a limited profit-element approach could survive.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Tue, 11 Feb 2025 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=468845</guid>
    </item>
  </channel>
</rss>