https://www.taxtmi.com/caselaws?id=794071 Section 68 addition on share capital and share premium received from a non-resident holding company was not sustainable where the investor's identity, the transaction's nature, and the explained source of funds were accepted; the proviso to Section 68 was treated as inapplicable to a non-resident investor, so the deletion of the addition was upheld. An ad hoc 10% disallowance of business expenditure also failed because the assessee furnished supporting details and the Assessing Officer identified no specific defect, inflation, non-business use, or rational basis for the percentage adopted; the deletion of that disallowance was likewise upheld. en-us Tue, 09 Jun 2026 00:00:00 +0530 Mon, 29 Jun 2026 09:28:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794071 Section 68 addition on share capital and share premium received from a non-resident holding company was not sustainable where the investor's identity, the transaction's nature, and the explained source of funds were accepted; the proviso to Section 68 was treated as inapplicable to a non-resident investor, so the deletion of the addition was upheld. An ad hoc 10% disallowance of business expenditure also failed because the assessee furnished supporting details and the Assessing Officer identified no specific defect, inflation, non-business use, or rational basis for the percentage adopted; the deletion of that disallowance was likewise upheld. Case-Laws Income Tax Tue, 09 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794071