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 271AA - failure to make disclosures, as required u/s 92E - as to whether SPMCECL was a related party is an issue qua which there can possibly be more than one view. Assessee has taken a stand that the legal advice that it received seems to indicate that it was not a related party. CIT(A) has done its own analysis of the Chinese Law and concluded that it was a related party to the transaction and hence required disclosure. - No penalty being reasonable cause shown - HC
Penalty u/s 271AA - failure to make disclosures, as required u/s 92E - as to whether SPMCECL was a related party is an issue qua which there can possibly be more than one view. Assessee has taken a stand that the legal advice that it received seems to indicate that it was not a related party. CIT(A) has done its own analysis of the Chinese Law and concluded that it was a related party to the transaction and hence required disclosure. - No penalty being reasonable cause shown - HC
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