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...
Export income - The expressions “derived from” and “since” are used in multiple instances in the Act. - Deduction u/s 80HHC - Unless the context does not permit, the construction of the expression “derived from” must be consistent. - The strict interpretation is in line with a few relative words, namely, manufacturer, exporter, purchaser of goods, etc. adverted to in Section 80HHC - Including other income as an eligible deduction would be counter-productive to the scope, purpose, and object of Section 80 HHC - Appeal of the assessee dismissed - SC
Export income - The expressions “derived from” and “since” are used in multiple instances in the Act. - Deduction u/s 80HHC - Unless the context does not permit, the construction of the expression “derived from” must be consistent. - The strict interpretation is in line with a few relative words, namely, manufacturer, exporter, purchaser of goods, etc. adverted to in Section 80HHC - Including other income as an eligible deduction would be counter-productive to the scope, purpose, and object of Section 80 HHC - Appeal of the assessee dismissed - SC
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