Just a moment...

Top
Help
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback

Contact Us At :

E-mail: [email protected]

Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
Add to...
You have not created any category. Kindly create one to bookmark this item!
Create New Category
Hide
Title :
Description :
❮❮ Hide
Default View
Expand ❯❯
Close ✕
🔎 TMI Notes - Adv. Search
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws----
  • ---- All Laws----
  • Benami Property
  • Bill
  • Central Excise
  • Companies Law
  • Customs
  • DGFT
  • FEMA
  • GST
  • GST - States
  • IBC
  • Income Tax
  • Indian Laws
  • Money Laundering
  • SEBI
  • SEZ
  • Service Tax
  • VAT / Sales Tax
Types:
---- All Types ----
  • ---- All Types ----
  • Act Rules
  • Case Laws
  • Circulars
  • Manuals
  • News
  • Notifications
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
    Manuals Income Tax
    Example:-X is employed by a company. He has been provided a car (1200cc) owned by employer, cost of ...
    Manuals Income Tax
    Example:- X, a director-employee of a private sector company based at Indore (population: 24Lakhs),...
    Manuals Income Tax
    Example:-X, an employee of ABC Ltd., posted at Ajmer (population: 18 Lakh), draws ₹ 3,00,000 a...
    Manuals Income Tax
    Example:-X has received following amount during the previous year. Basic Salary 7,000 p.m.; Dearness...
    Manuals Income Tax
    Example:-Mr. X received voluntary retirement compensation of ₹ 7,00,000 after 30 years 4 month...
    Manuals Income Tax
    Example:-Mr. X received retrenchment compensation of ₹ 10,00,000 after 30 years 4 months of se...
    Manuals Income Tax
    Example:-Mr. X retired from ABC Ltd. on 11th March 2014 after serving for 30 years and 11 months and...
    Manuals Income Tax
    Example:-X retires from B Ltd. on 31st July, 2014. He gets pension of ₹ 1,000 per month up to ...
    Manuals Income Tax
    Example:-An employee of X Ltd. retires on 10th March, 2015 after service of 26 years and receives &#...
    Manuals Income Tax
    Example:-X, an employee of A Ltd., receives ₹ 62,000 as gratuity (he is covered under the Paym...
    Manuals Income Tax
    Example:- X, an employee of Central Govt., receives 9,20,000 as gratuity at the time of his retirem...
    Case Laws Central Excise
    Applicability of a Circular issued by the Board - Prospective or Retrospective - Demand of duty prio...
    Manuals Service Tax
    Whether there is any provision regarding refund of application fee if applicant withdraw the applica...
    Manuals Service Tax
    Whether Advance Ruling Authority can reconsider or review its own order after giving final answer on...
    Manuals Service Tax
    Whether Advance Ruling application can be filed for a question related to Circular issued by the Cen...
    Manuals Service Tax
    Whether a Government company can apply for a advance ruling ? if yes, whether subsidiary of a govern...
    Manuals Service Tax
    Whether appeal can be filed against the order of Advance Ruling Authority ? If no, whether there is ...
    Manuals Service Tax
    Whether an appeal can be filed by the person on an entirely different ground, in whose favour decisi...
    Manuals Service Tax
    Whether appeal filed by the person other than aggrieved party is maintainable?
    Manuals Service Tax
    Whether an appeal can be restored by filing fresh appeal which was earlier rejected on some grounds?
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Notes
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries
Manuals Income Tax
Show AI Summary
Perquisite valuation of employer provided motor car treats engine capacity, driver cost, recoveries and private use depreciation.
Perquisite valuation for employer provided motor cars uses a fixed monthly valuation for car and driver where engine capacity falls below the higher threshold; recoveries from the employee do not reduce that fixed valuation. If the vehicle is used exclusively for private purposes, the taxable perquisite is calculated as annual depreciation plus petrol, driver and maintenance costs, minus any amount recovered from the employee.
Manuals Income Tax
Show AI Summary
Rent-free accommodation valuation: taxable value is the lower of a percentage of salary or employer-paid rent for perquisite computation.
Taxable value of a rent-free accommodation perquisite is the lower of (a) 15% of salary (computed as basic salary plus DA plus commission) and (b) employer paid annual rent. In the example the aggregated annual basic, DA and commission are used to calculate the 15% benchmark, which is then compared with the annual lease rent to determine the taxable perquisite.
Manuals Income Tax
Show AI Summary
Taxable value of rent-free accommodation set at a percentage of salary when city population exceeds threshold.
Taxable perquisite for rent free accommodation is computed by applying the population based percentage to Salary, defined to include Basic, DA (forming part of salary) and Commission; the taxable value equals the prescribed percentage of that aggregated salary.
Manuals Income Tax
Show AI Summary
House Rent Allowance exemption under section 10(13A) requires choosing the minimum of three salary-based tests to determine taxable HRA.
The exemption under section 10(13A) and Rule 2A is the minimum of actual HRA received, rent paid in excess of ten percent of salary, and the prescribed percentage of salary. In the example actual HRA is 36,000; excess rent over ten percent of salary is 26,400; forty percent of salary is 38,400. The exempt amount is therefore 26,400 and the remaining 9,600 is included in gross salary.
Manuals Income Tax
Show AI Summary
Voluntary retirement compensation tax treatment: exemption limited by statutory ceiling formulas; excess is treated as taxable salary.
Computation of taxability of voluntary retirement compensation is governed by a statutory exemption limited by prescribed ceiling formulas and the principle that the exempt amount is the lesser of specified sums. In the example, compensation received of 700,000 gives an exempt amount of 500,000 under the statutory ceiling, leaving 200,000 as taxable salary under the governing exemption provision and associated rules.
Manuals Income Tax
Show AI Summary
Retrenchment compensation exemption under Sec. 10(10B): apply least-of-three test for calculating taxable retrenchment; excess taxable.
Computation of retrenchment compensation exemption under Sec. 10(10B): compute the three comparator sums using the employee's service length and salary components, take the least of those sums as exempt. In the example the exempt amount is Rs. 4,32,692 and the remaining Rs. 5,67,308 of the retrenchment payment is taxable.
Manuals Income Tax
Show AI Summary
Leave salary exemption under section 10(10AA) limited by average salary and statutory caps, yielding the lowest applicable ceiling.
Computation of leave salary exemption under section 10(10AA) requires determining average salary by annualising ten months' basic pay plus the proportion of dearness allowance included for retirement benefits and dividing by ten. Unavailed leave months equal total entitlement minus leaves taken and leaves earlier encashed. The exempt leave salary is the least of (unavailed months x average salary), (ten months' average salary), and the statutory ceilings; the example selects the lowest applicable ceiling as exempt.
Manuals Income Tax
Show AI Summary
Commuted pension tax treatment: part exempt, part taxable; exemption reduced where gratuity is received.
Uncommuted pension is fully taxable as salary; commuted pension is partly exempt and partly taxable. Compute a notional full pension value from the commuted payment and apply an exemption fraction: if no gratuity is received, one half of the notional full pension value is exempt; if gratuity is received, one third is exempt. The remainder of the commuted payment is chargeable to tax as salary and must be added to taxable uncommuted pension to determine total taxable pension income.
Manuals Income Tax
Show AI Summary
Gratuity exemption: least of three test determines exempt portion for noncovered employers; excess gratuity is taxable.
Gratuity from a noncovered employer is exempt to the extent of the least of three amounts: the service based fraction computed from the average monthly salary (which includes basic pay, one month's dearness allowance, and average monthly commission), the statutory monetary ceiling, and the gratuity actually received; any excess over that exempt amount is taxable.
Manuals Income Tax
Show AI Summary
Gratuity exemption: part determined by 15 days salary times completed years, excess treated as taxable salary.
Gratuity exemption is determined by taking the least of: the product of 15 days' salary and completed years of service, the statutory ceiling, and the gratuity received. Completed years may be rounded to include qualifying months. The exempt portion is that least amount; any excess over the exempt amount is taxable as salary income in the assessment year.
Manuals Income Tax
Show AI Summary
Gratuity exemption under Section 10(10)(i) remains available even if retiree accepts private sector employment after retirement.
Gratuity paid to a government employee on retirement is fully exempt from income tax under the governing gratuity exemption provision, and that exemption remains available even if the retiree subsequently accepts employment in the private sector.
Case Laws Central Excise
Show AI Summary
Prospective effect of administrative circulars: "henceforth" signals non-retrospective application, barring past-duty demands.
When the Board uses language such as "henceforth" a circular is to be treated as having prospective effect; consequently, if the Board did not intend retrospective application, the circular cannot support demands for duties predating its issuance.
Manuals Service Tax
Show AI Summary
Refund of application fee: advance ruling applications are not refundable even if the applicant withdraws the application.
There is no statutory or regulatory provision permitting refund of fees paid for advance-ruling applications; fees are retained and not returned on withdrawal, a position noted in the Service Tax Practice Manual and reflected in the Authority for Advance Rulings decision cited.
Manuals Service Tax
Show AI Summary
Advance ruling review barred except when ruling procured by fraud or misrepresentation, enabling annulment under law.
The Authority for Advance Rulings lacks jurisdiction to reconsider or review its own ruling absent a substantiated mistake of law or fact or a mistake apparent from the record warranting rectification or amendment under the procedural regulations; however, a previously announced ruling may be declared void ab initio if it is shown to have been obtained by fraud or misrepresentation of facts.
Manuals Service Tax
Show AI Summary
Advance ruling jurisdiction excludes Board circulars; notifications by the government are distinct and control admissibility.
Advance ruling jurisdiction does not extend to Board circulars because the statute expressly contemplates government notifications for advance-ruling purposes while omitting circulars; the power to issue circulars is conferred on the Board under the Central Excise framework made applicable to service tax, whereas notification-making power in the service-tax provisions is vested in the Central Government, producing a statutory limitation on advance-ruling admissibility.
Manuals Service Tax
Show AI Summary
Government company eligibility for advance ruling confirmed; subsidiaries retain separate legal personality and may also apply.
A government company is eligible to apply for an advance ruling and a subsidiary of a government company may also file because the holding company and each subsidiary are separate legal entities with independent rights to apply; a step-down subsidiary falls within the definition of an applicant, rendering its advance-ruling application maintainable.
Manuals Service Tax
Show AI Summary
Writ remedy against advance rulings where no statutory appeal exists; seek High Court review under constitutional writ jurisdiction.
No statutory appeal exists against orders of the Advance Ruling Authority; the available remedial route is a writ petition invoking constitutional writ jurisdiction in the appropriate High Court. The Supreme Court has indicated parties should approach the High Court rather than seek direct original jurisdiction at the apex court, and courts are urged to allocate and expedite fiscal writ matters.
Manuals Service Tax
Show AI Summary
Appeal on new grounds barred where party lacks aggrievement; omitted issues may be raised later upon arising.
An appellant cannot maintain an appeal on entirely new grounds if the assessing or appellate authority has approved the assessee's classification or fully allowed the revenue's prayer, because there is no aggrievement; however, issues not considered by the tribunal may be agitated later when a cause of action arises.
Manuals Service Tax
Show AI Summary
Locus standi limits: only aggrieved private parties may challenge tax notices; third-party appeals are not maintainable.
Only the private operators against whom tax notices are issued possess the requisite standing to challenge those notices; third parties lack authority to prosecute appeals or writs on their behalf, and challenges must be instituted by the directly aggrieved parties through the statutory remedy, who may then raise all issues available to them in accordance with law.
Manuals Service Tax
Show AI Summary
Finality of tribunal orders bars fresh appeals, preventing restoration by filing a new appeal against the same order.
When an appeal has been rejected by the Tribunal there is no scope for entertaining an application for restoration by filing a fresh appeal in respect of the same order; similarly, once a Tribunal order has become final for lack of further appeal, the finality of orders precludes fresh appeals challenging that same order.

TMI Notes

Back

All TMI Notes

Showing Results for :
Reset Filters
No Records Found

TMI Notes

Back

All TMI Notes

whatsapp Join Channel
Showing Results for : Reset Filters

Section 68, Loan Credits, and the Limits of Suspicion: Evidentiary Discipline in Search-Linked Assessments

29 December, 2025

Contents
Acts
Rules & Regulations
Plus +
Summary
Note

Note

-

Bookmark

Print

Print

Deciphering Legal Judgments: A Comprehensive Analysis of Judgment

Reported as:

2025 (12) TMI 780 - ITAT DELHI

Introduction

The decision of the Income Tax Appellate Tribunal, Delhi  concerns a cluster of Revenue appeals arising from appellate orders u/s 250 of the Income-tax Act, 1961 ("the Act"). The core controversy across years and entities was uniform: whether unsecured loans received from a non-banking financial company ("NBFC lender") could be treated as unexplained cash credits u/s 68 (with consequential tax implications u/s 115BBE), largely on the basis of (i) statements recorded in earlier search proceedings involving alleged entry providers, and (ii) a Ministry of Finance press release allegedly "red-flagging" the lender as a shell entity.

The Tribunal treated one year as the "lead" matter and disposed the remaining appeals by applying the same reasoning, also extending the consequence to associated interest disallowances. The ruling is significant within the broader legal framework governing section 68 because it revisits three recurring fault-lines in search-linked assessments and reassessments: (a) the evidentiary standard for branding bank-routed loans as accommodation entries, (b) the limits of the "source of source" enquiry for loan credits in years prior to the Finance Act, 2022 amendments, and (c) procedural fairness when the first appellate authority conducts independent enquiries u/s 250(4) vis-`a-vis Rule 46A.

Key Legal Issues

  • Section 68 test for unsecured loans: Whether the assessee companies discharged the burden of proving identity, genuineness, and creditworthiness of the lender, and whether the Assessing Officer ("AO") had legally sustainable grounds to reject that explanation.

  • Reliance on statements without corroboration: Whether additions could rest substantially on third-party statements (including statements recorded years earlier) without contemporaneous incriminating material or transaction-specific evidence.

  • "Source of source" for loan credits: Whether the AO was entitled (for the relevant assessment years) to insist on proof of the lender's upstream sources, and whether treating repayments of earlier advances as "fresh borrowings" was legally and factually correct.

  • Use of administrative press release as substantive evidence: Whether a press release branding entities as shell/high-risk could, by itself, justify section 68 additions absent regulatory or investigative confirmation.

  • Rule 46A and section 250(4): Whether the first appellate authority violated Rule 46A by considering material obtained during appellate proceedings, and whether the AO was afforded adequate opportunity to respond.

  • Effect of loan repayment and double taxation concerns: Whether repayment in later years and/or alleged taxation of the same credits in the lender's hands undermined additions in the borrowers' hands.

Detailed Issue-wise Analysis

1) Section 68: Identity, genuineness, and creditworthiness

The Tribunal reaffirmed the orthodox section 68 framework: where a credit appears in the books, the assessee must provide a satisfactory explanation of its nature and source. In loan cases, courts consistently require demonstration of (i) identity of creditor, (ii) genuineness of transaction, and (iii) creditor's creditworthiness.

On facts, the Tribunal recorded that the assessee companies had furnished the standard documentary set: confirmations, bank statements of the lender, audited financials, and income-tax return acknowledgements. Importantly, the lender was an RBI-registered NBFC, and the transactions were through banking channels. The Tribunal emphasized that the AO's inference of non-creditworthiness could not override documentary evidence unless the AO brought cogent contrary material establishing that the funds were assessee's own money routed back, or that the lender lacked capacity despite apparent bank balances.

The Tribunal also noted an internal inconsistency: the AO accepted part of the funding chain as genuine (including certain funds traced to large, credible sources) but treated other portions as unexplained without demonstrating a transaction-specific defect. The Tribunal treated this "partial acceptance on identical facts" as weakening the AO's conclusion that the entire lender was merely an accommodation conduit.

2) Statements as sole basis: corroboration and "cherry-picking"

A major plank of the Revenue case was reliance on statements of persons alleged to be involved in accommodation entries, including older statements recorded in prior search actions. The Tribunal accepted the appellate finding that "standalone statements without corroborative evidence" cannot, by themselves, sustain section 68 additions when documentary loan evidence exists.

The Tribunal reproduced and approved the appellate reasoning that the AO selectively relied on statements supporting the Revenue narrative while ignoring other statements that were adverse to that narrative. It treated such selective reliance as a defect in appreciation of evidence, aligning with the principle that statements must be evaluated holistically and, where disputed, supported by independent material.

In this context, the Tribunal leaned on higher judicial authority for the proposition that additions made "solely based on statements" without deeper probing into documentary records are unsustainable. It expressly relied on the Supreme Court's approach in Principal Commissioner of Income-tax v. Dwarka Prasad Aggarwal [2024 (4) TMI 607 - SC ORDER] (cited in the order) to reject statement-only additions, as well as the broader rule that suspicion cannot substitute proof (Umacharan Shaw & Bros. [1959 (5) TMI 11 - SUPREME COURT]; Dhakeswari Cotton Mills [1954 (10) TMI 12 - SUPREME COURT (LB)]).

3) Incriminating material and search-era jurisprudence

Although the additions arose through reassessment proceedings, the factual background involved search actions and reliance on search statements. The Tribunal therefore invoked the jurisprudence that additions should not be made "dehors incriminating material" and that seized material must be assessment-year-specific and transaction-linked in search regimes.

The Tribunal cited CIT v. Singhad Education Society [2017 (8) TMI 1298 - SUPREME COURT] to emphasize the need for correlation of incriminating material with the relevant year, and PCIT v. Abhisar Buildwell (P.) Ltd. [2023 (4) TMI 1056 - SUPREME COURT] for the principle that additions cannot be made absent incriminating material. While strictly these rulings arise in the section 153A/153C context, the Tribunal used them to reinforce the evidentiary discipline required when the Revenue narrative is search-driven but the assessment record lacks seized, transaction-specific proof implicating the impugned loan.

4) "Source of source" for loans and the Finance Act, 2022 amendment

The AO's approach substantially examined the lender's upstream credits and treated the alleged weak credentials of entities upstream as destroying the lender's creditworthiness. The Tribunal accepted the appellate finding that many immediate credits in the lender's bank were repayments of earlier advances, not fresh loans. As a result, the AO's criticism of the upstream entities' creditworthiness was treated as misplaced: repayment of an advance is conceptually different from a fresh extension of credit to the lender that would require a separate capacity analysis for the relevant year.

On law, the Tribunal held that the specific "source of source" obligation for loan/borrowing credits (as introduced via Finance Act, 2022 by adding a proviso expanding explanation requirements) applies from assessment year 2023-24 onwards. For the years under consideration, the Tribunal treated insistence on proving upstream sources for non-share-capital loans as not mandated by statute, though it also noted that the assessees had, in fact, furnished a detailed explanation of credits in the lender's bank account.

The Tribunal referred to coordinate bench reasoning (including decisions cited in the order) that earlier section 68 amendments empowering deeper enquiries were historically focused on share capital/share premium contexts and not a general "source of source" rule for all loans for pre-amendment years.

5) Press release "shell company" allegation and independent verification

The Revenue argued that the lender was a "confirmed shell company" as per a Ministry of Finance press release and was categorized "high risk" by a financial intelligence authority for compliance failures. The appellate authority, exercising section 250(4), made an independent enquiry from the Serious Fraud Investigation Office (SFIO) and received a written confirmation that no investigation was initiated/pending/disposed against the lender. This was treated as undermining the AO's reliance on the press release as determinative evidence.

The Tribunal endorsed this approach. It treated the press release as, at best, an administrative flag, insufficient to displace documentary proof of real banking transactions and statutory compliance-particularly when the designated nodal authority did not confirm any proceedings.

6) Rule 46A versus section 250(4): appellate powers and opportunity to AO

Revenue also challenged the deletion on the ground that additional evidence was admitted in violation of Rule 46A. The Tribunal rejected this objection by affirming the distinction between:

  • Assessee-led additional evidence tendered u/r 46A; and

  • Evidence gathered by the appellate authority through independent enquiry u/s 250(4).

The Tribunal relied upon the principle (citing the Delhi High Court decision in CIT v. Manish Buildwell (P.) Ltd. [2011 (11) TMI 35 - DELHI HIGH COURT]) that where the appellate authority invokes section 250(4) suo motu, the strict Rule 46A conditions do not apply in the same manner. Crucially, the Tribunal noted repeated opportunities were provided to the AO (multiple reminders) to comment on enquiry results and materials, but the AO did not respond. This factual finding was decisive in negating procedural prejudice.

7) Repayment of loans and "double taxation" considerations

The appellate authority also relied on loan repayment in subsequent years and the contention that similar credits had already been subjected to tax in the lender's hands, making borrower-side additions duplicative. The Tribunal accepted repayment as a relevant corroborative factor supporting genuineness (especially where repayments are through banking channels and not questioned in later years). It also accepted the inequity of taxing the same stream multiple times, observing that once the underlying bank credits are already brought to tax in the lender's assessments, borrower-side taxation without fresh incriminating proof risks impermissible duplication.

While repayment alone is not a statutory exemption u/s 68, the Tribunal treated it as strengthening the inference that the transaction was not a sham entry-particularly when paired with confirmations, bank trail, and lack of cash-deposit evidence at the point of lending.

Key Holdings and Reasoning

Ratio (Operative principles)

  • Section 68 additions for bank-routed unsecured loans cannot be sustained where the assessee furnishes confirmations, bank statements, audited financials and tax particulars of the lender, and the AO relies primarily on uncorroborated statements/press releases without transaction-specific incriminating material.

  • For years prior to AY 2023-24, "source of source" for loan/borrowing credits is not a statutory requirement in the manner introduced by the Finance Act, 2022; in any event, where upstream credits are repayments of earlier advances, treating them as fresh borrowings is erroneous.

  • Material obtained by the appellate authority via section 250(4) enquiry is not to be equated with Rule 46A additional evidence, particularly when the AO is given opportunity to respond and fails to do so.

Obiter (Persuasive observations)

  • The Tribunal's broader reliance on "no addition dehors incriminating material" search jurisprudence, while persuasive in the search ecosystem, may be viewed as context-enhancing rather than strictly necessary in a reassessment setting; it serves to reinforce the evidentiary threshold when the Revenue case is search-statement driven.

  • Observations on "partial acceptance" of lender capacity by the AO suggest an expectation of consistent treatment of identical evidentiary patterns; while fact-sensitive, it signals a judicial intolerance for selective acceptance absent principled differentiation.

The Tribunal consequently dismissed all Revenue appeals, and-since the principal loans were held genuine-also upheld deletion of interest disallowances linked to those loans.

Conclusion

This decision consolidates a practical, evidence-centric approach to section 68 in loan cases: documentary proof and bank trail cannot be displaced by generalized allegations of "entry provider" behaviour unless the Revenue demonstrates a direct nexus between the impugned loan and an accommodation cash trail or other incriminating material. The ruling also clarifies procedural robustness of appellate fact-finding u/s 250(4), particularly when the AO is afforded opportunities but remains non-responsive.

For future disputes, the case underscores that administrative "shell entity" lists or press releases, without confirmation from competent investigative/regulatory outcomes and without transaction-specific evidence, are weak foundations for section 68 additions. It further anticipates a sharper litigation divide post-AY 2023-24, where the amended section 68 framework will likely expand legitimate "source of source" enquiries for loan credits; however, even under the amended regime, the Revenue's conclusions will still need to be evidence-led rather than inference-led.

A likely future development is the evolution of standards on when taxation in the lender's hands should restrain borrower-side additions to prevent duplicative taxation. Clear administrative guidance or statutory coordination mechanisms (especially where the Department simultaneously taxes bank credits in the lender and the corresponding receipts in borrowers) could reduce inconsistent outcomes and repetitive litigation.

 


Full Text:

2025 (12) TMI 780 - ITAT DELHI

Topics

Acts Income Tax