The tribunal observed that the estimated interest on loans to friends and relatives cannot be taxed without evidence of actual utilisation and receipts. The ruling emphasises natural justice and the need for proper substantiation before making notional additions to taxable income.

The Tribunal found the reduction commercially justified and non-prejudicial to shareholders or creditors. The ruling underscores that surplus capital may be returned when operational focus changes and statutory compliance is ensured.

The Tribunal found the reduction commercially justified and non-prejudicial to shareholders or creditors. The ruling underscores that surplus capital may be returned when operational focus changes and statutory compliance is ensured.