“Section 42(6)(a)”
The decision most relied on for Section 42(6)(a) is CIT v. N.R. Portfolio (P.) Ltd. (42 Taxmann.com 339), cited in 252 judgments on BharatTax.
Leading authorities on Section 42(6)(a)
For cash credit additions under Section 68, establishing the 'identity' of a creditor requires more than just producing PAN or assessment particulars; it necessitates demonstrating their actual business operations, place of work, staff, and public recognition. This rigorous standard ensures the assessee proves the identity, creditworthiness, and genuineness of the transaction.
A transaction, even if appearing to be in the capital field or recorded as such, can constitute an 'adventure in the nature of trade,' leading to taxable income from business rather than capital gains.
Cash sales and their corresponding cash deposits are a regular feature of business activities for an assessee, even if buyer details are not consistently recorded on invoices.
Interest expenditure cannot be disallowed under Section 14A if investments are made for business purposes, such as maintaining liquid funds for large government orders.
