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...
Levy of penalty on Director u/r 26 of CER - involvement of the director of the appellants in clandestine activities or not - here are not much reasoning has been assigned by the said order, to show that Director was having mens rea or direct involvement for invocation of Rule 26 - Since the impugned order fails to establish the ingredient of “mens rea” on the part of the Appellant 2 who was otherwise performing their duties as employee of the company, the penalties imposed on the Director, cannot be upheld. - AT
Levy of penalty on Director u/r 26 of CER - involvement of the director of the appellants in clandestine activities or not - here are not much reasoning has been assigned by the said order, to show that Director was having mens rea or direct involvement for invocation of Rule 26 - Since the impugned order fails to establish the ingredient of “mens rea” on the part of the Appellant 2 who was otherwise performing their duties as employee of the company, the penalties imposed on the Director, cannot be upheld. - AT
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