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...
Unexplained investment - the Ld. AO has himself mentioned in Para 12.1 “The excel sheet does not contain the year wise breakup. A reasonable estimate of these year wise is as under”. This categorical mention by Ld. AO clearly admits that there was no basis for attributing the transactions to AY 2009-10 under consideration. - No additions - AT
Unexplained investment - the Ld. AO has himself mentioned in Para 12.1 “The excel sheet does not contain the year wise breakup. A reasonable estimate of these year wise is as under”. This categorical mention by Ld. AO clearly admits that there was no basis for attributing the transactions to AY 2009-10 under consideration. - No additions - AT
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