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 271(1)(c) - debatable issue - Since the assessee-respondent had not suppressed the amount in question and had disclosed it in its return, merely because he declared it under a particular “head of income”, and the AO chose to treat the same under some other head, the assessee-respondent cannot be accused of furnishing incorrect particulars of income or suppressing facts. - HC
Penalty u/s 271(1)(c) - debatable issue - Since the assessee-respondent had not suppressed the amount in question and had disclosed it in its return, merely because he declared it under a particular “head of income”, and the AO chose to treat the same under some other head, the assessee-respondent cannot be accused of furnishing incorrect particulars of income or suppressing facts. - HC
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