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 u/s 68 - Head changed from income under “PGBP” (as shown by the assessee) to addition U/s 68 - That there was some tax sought to be evaded by assessee, is a necessary condition for imposition of penalty U/s 271(1)(c) - The allegation of the Ld. CIT(A) that the assessee had the bogus income or bogus credit, is pointless, because the corresponding amount was already included in the returned income of the assessee. - AT
Penalty u/s 271(1)(c) - Addition u/s 68 - Head changed from income under “PGBP” (as shown by the assessee) to addition U/s 68 - That there was some tax sought to be evaded by assessee, is a necessary condition for imposition of penalty U/s 271(1)(c) - The allegation of the Ld. CIT(A) that the assessee had the bogus income or bogus credit, is pointless, because the corresponding amount was already included in the returned income of the assessee. - AT
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