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...
Scope of Black Money (Undisclosed Foreign Income & Assets) And Imposition of Tax Act 2015 - If we are to hold that definition of ‘beneficial owner’ as assigned by Explanation 4 to Section 139(1) is to equally apply, we will end up in a situation in which the BMA itself will become unworkable. Therefore, for both of these reasons- i.e. (a) the contextual requirements being otherwise, and (b) the adoption of this meaning rendering the provisions of BMA becoming unworkable, the definition under Explanation 4 to Section 139(1) cannot be adopted in the context of the BMA. We reject this plea of the learned counsel as well. - AT
Scope of Black Money (Undisclosed Foreign Income & Assets) And Imposition of Tax Act 2015 - If we are to hold that definition of ‘beneficial owner’ as assigned by Explanation 4 to Section 139(1) is to equally apply, we will end up in a situation in which the BMA itself will become unworkable. Therefore, for both of these reasons- i.e. (a) the contextual requirements being otherwise, and (b) the adoption of this meaning rendering the provisions of BMA becoming unworkable, the definition under Explanation 4 to Section 139(1) cannot be adopted in the context of the BMA. We reject this plea of the learned counsel as well. - AT
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