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 - entries through journal entries - Violation of provisions of section 269SS - round tripping of funds to evade taxes - proof of reasonable cause u/s 273B - these transactions were not made by the assessee with a malafide intent to evade tax and that there is no evidence brought on record to even remotely suggest that the assessee company by passing the aforesaid journal entries had sought to introduce its unaccounted income into the system. - it could be safely concluded that these entries neither reflect any receipt of loan nor repayment of loan. - AT
Penalty u/s 271D - entries through journal entries - Violation of provisions of section 269SS - round tripping of funds to evade taxes - proof of reasonable cause u/s 273B - these transactions were not made by the assessee with a malafide intent to evade tax and that there is no evidence brought on record to even remotely suggest that the assessee company by passing the aforesaid journal entries had sought to introduce its unaccounted income into the system. - it could be safely concluded that these entries neither reflect any receipt of loan nor repayment of loan. - AT
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