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) - when the assessee company had been assessed to tax under the deeming provisions of Sec. 115JB of the Act, therefore, on the basis of our aforesaid observations no penalty u/s 271(1)(c) in respect of additions/ disallowances made under the normal provisions of the Act could have been imposed upon the assessee. - As the case of the assessee before us is for A.Y 2014-15 therefore, the post-amended ‘Explanation 4’ to Sec. 271(1)(c) would not be applicable in its case. - AT
Penalty u/s 271(1)(c) - when the assessee company had been assessed to tax under the deeming provisions of Sec. 115JB of the Act, therefore, on the basis of our aforesaid observations no penalty u/s 271(1)(c) in respect of additions/ disallowances made under the normal provisions of the Act could have been imposed upon the assessee. - As the case of the assessee before us is for A.Y 2014-15 therefore, the post-amended ‘Explanation 4’ to Sec. 271(1)(c) would not be applicable in its case. - AT
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