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) - addition of deemed dividend u/s 2(22)(e) - the explanation of the transaction being commercial in nature for purchase of property - the explanation did not save it from the rigors of 2(22)(e), and therefore if the same was found false, it could not be said that the assessee had malafidely not returned the deemed income to tax - no penalty
Penalty u/s 271(1)(c) - addition of deemed dividend u/s 2(22)(e) - the explanation of the transaction being commercial in nature for purchase of property - the explanation did not save it from the rigors of 2(22)(e), and therefore if the same was found false, it could not be said that the assessee had malafidely not returned the deemed income to tax - no penalty
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