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 - allegation of accommodation entries taken by assessee - initial burden to prove - once the initial burden is discharged by the assessee the burden shifts to the revenue to disprove the claim of the assessee. It is noticed that AO did not make any sort of enquiries to disprove the genuineness of the transaction on the evidences furnished by the assessee. He has completely ignored even the statement retracted by the PKJ. The addition is made merely on surmises and conjectures without probing further by the Assessing Officer. - AT
Addition u/s. 68 - allegation of accommodation entries taken by assessee - initial burden to prove - once the initial burden is discharged by the assessee the burden shifts to the revenue to disprove the claim of the assessee. It is noticed that AO did not make any sort of enquiries to disprove the genuineness of the transaction on the evidences furnished by the assessee. He has completely ignored even the statement retracted by the PKJ. The addition is made merely on surmises and conjectures without probing further by the Assessing Officer. - AT
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