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...
Addition u/s 68 - availability of source and application of fund - Cash in hand - AO ought to have made cash flow statement with opening cash balance, deposit and withdrawal and given due credit for the available sources. Instead, the AO chosen to tax the entire investments without giving credit for the available sources. No hesitation to agree with the view of the CIT(A) that the AO did not appreciate the issues properly. - AT
Addition u/s 68 - availability of source and application of fund - Cash in hand - AO ought to have made cash flow statement with opening cash balance, deposit and withdrawal and given due credit for the available sources. Instead, the AO chosen to tax the entire investments without giving credit for the available sources. No hesitation to agree with the view of the CIT(A) that the AO did not appreciate the issues properly. - AT
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