Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Section 144B did not apply where the assessment was made by the jurisdictional Assessing Officer outside the faceless-assessment framework and mandatory notices had been issued; procedural non-observance therefore did not invalidate the assessment. Rejection of books of account and profit estimation in online share trading require substantial accounting discrepancies and adherence to best judgment principles. Absence of matching bank credits or an adverse turnover-to-expense ratio alone was insufficient where broker-mediated pay-ins and payouts, regular accounting methods, and transactional evidence were not properly considered. Profit estimation must have a rational, business-specific basis rather than rely on guesswork; the estimated profit addition was deleted.
Section 144B did not apply where the assessment was made by the jurisdictional Assessing Officer outside the faceless-assessment framework and mandatory notices had been issued; procedural non-observance therefore did not invalidate the assessment. Rejection of books of account and profit estimation in online share trading require substantial accounting discrepancies and adherence to best judgment principles. Absence of matching bank credits or an adverse turnover-to-expense ratio alone was insufficient where broker-mediated pay-ins and payouts, regular accounting methods, and transactional evidence were not properly considered. Profit estimation must have a rational, business-specific basis rather than rely on guesswork; the estimated profit addition was deleted.
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