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 270A - “underreporting” of income - right to be granted immunity under Section 270AA - In the present case, the petitioner has satisfied the aforesaid conditions, inasmuch as, (i) the tax has been paid on the additions; (ii) appeal has undisputedly not been filed; and (iii) penalty (as would be evident from the penalty notice) has been initiated on account of “underreporting” of income. - the impugned order under Section 270A of the Act is set aside and the respondents are directed to grant immunity under Section 270AA - HC
Penalty u/s 270A - “underreporting” of income - right to be granted immunity under Section 270AA - In the present case, the petitioner has satisfied the aforesaid conditions, inasmuch as, (i) the tax has been paid on the additions; (ii) appeal has undisputedly not been filed; and (iii) penalty (as would be evident from the penalty notice) has been initiated on account of “underreporting” of income. - the impugned order under Section 270A of the Act is set aside and the respondents are directed to grant immunity under Section 270AA - HC
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