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...
Substantive protective additions - CIT(A) has already placed reliance on the CBDT circulars that such admissions or confessions; as the case may be, made during the course of a search or survey does not carry any evidentiary value since it has to be only to the evidence collected only. We thus find no reason to interfere with the learned CIT(A)’s impugned conclusion deleting “substantive” and “protective” additions in issue - AT
Substantive protective additions - CIT(A) has already placed reliance on the CBDT circulars that such admissions or confessions; as the case may be, made during the course of a search or survey does not carry any evidentiary value since it has to be only to the evidence collected only. We thus find no reason to interfere with the learned CIT(A)’s impugned conclusion deleting “substantive” and “protective” additions in issue - AT
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