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...
Penalty u/s 271D - contravention of provisions of Sections 269SS - assessee has accepted loans and deposits from various sister concerns through journal entries, as such, loans were not taken through an account payee cheque or account payee bank drafts - it could be safely concluded that these entries were passed out of business constraints and exigencies and for administrative convenience with no malafide intent to evade payment of tax. In our considered opinion, this business constraint and exigency and administrative convenience itself constitutes reasonable cause within the meaning of section 273B - No penalty - AT
Penalty u/s 271D - contravention of provisions of Sections 269SS - assessee has accepted loans and deposits from various sister concerns through journal entries, as such, loans were not taken through an account payee cheque or account payee bank drafts - it could be safely concluded that these entries were passed out of business constraints and exigencies and for administrative convenience with no malafide intent to evade payment of tax. In our considered opinion, this business constraint and exigency and administrative convenience itself constitutes reasonable cause within the meaning of section 273B - No penalty - AT
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