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...
Penalty u/s 271(1)(c) - assessee claimed depreciation u/s 32 on road constructed on Build-Operate-Transfer basis which was denied - the Revenue had itself accepted that there was a doubt and that is why the clarification of 2014 was issued. Had it been so cut and dried there was no occasion for the Board to have issued the clarification and infact, this is precisely what weighed with CIT(A) and ITAT - no penalty
Penalty u/s 271(1)(c) - assessee claimed depreciation u/s 32 on road constructed on Build-Operate-Transfer basis which was denied - the Revenue had itself accepted that there was a doubt and that is why the clarification of 2014 was issued. Had it been so cut and dried there was no occasion for the Board to have issued the clarification and infact, this is precisely what weighed with CIT(A) and ITAT - no penalty
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