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...
Enhancement of penalty u/s 78 from 25% to 100% by the corrigendum order - WCS was highly litigated and lot of interpretation issues were there. Taking pragmatic view of the matter, it is found that there is no contumacious conduct on the part of the appellant and accordingly, the penalty under section 78 & section 77 is set aside - the corrigendum was issued beyond jurisdiction, and is a nonest in law. - AT
Enhancement of penalty u/s 78 from 25% to 100% by the corrigendum order - WCS was highly litigated and lot of interpretation issues were there. Taking pragmatic view of the matter, it is found that there is no contumacious conduct on the part of the appellant and accordingly, the penalty under section 78 & section 77 is set aside - the corrigendum was issued beyond jurisdiction, and is a nonest in law. - AT
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