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...
Revision u/s 263 - the ld. PCIT had alleged that the ld. AO had not made any enquiry at all on the issue of long term borrowings and other current liabilities. It is not the case of the PCIT that the ld. AO had indeed made enquiries but he had not made requisite entries thereon - Hence, in our considered opinion, the ld. PCIT grossly erred in invoking revisionary jurisdiction which is against the settled legal principles and more so in the facts and circumstances of the instant case. - AT
Revision u/s 263 - the ld. PCIT had alleged that the ld. AO had not made any enquiry at all on the issue of long term borrowings and other current liabilities. It is not the case of the PCIT that the ld. AO had indeed made enquiries but he had not made requisite entries thereon - Hence, in our considered opinion, the ld. PCIT grossly erred in invoking revisionary jurisdiction which is against the settled legal principles and more so in the facts and circumstances of the instant case. - AT
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