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...
Revision u/s 263 - depreciation claimed on goodwill arose out of amalgamation - PCIT has assumed jurisdiction u/s. 263 of the Act on the sole basis of application of 5th proviso to section 32(1) of the Act, towards depreciation on goodwill. In view of the factual matrix as stated in preceding paragraphs and non-applicability of 5th proviso to section 32(1) of the Income Tax Act, 1961, there cannot be error in relation to the view taken by the Assessing Officer while framing the original assessment. - AT
Revision u/s 263 - depreciation claimed on goodwill arose out of amalgamation - PCIT has assumed jurisdiction u/s. 263 of the Act on the sole basis of application of 5th proviso to section 32(1) of the Act, towards depreciation on goodwill. In view of the factual matrix as stated in preceding paragraphs and non-applicability of 5th proviso to section 32(1) of the Income Tax Act, 1961, there cannot be error in relation to the view taken by the Assessing Officer while framing the original assessment. - AT
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