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...
Characterization of receipt - Compensation receipt on termination of contract - Addition under Section 28(ii)(e) - The Tribunal differentiates between termination and non-renewal of a contract and argues that the compensation received due to non-renewal should not be treated as termination under Section 28(ii)(e) or Section 56(2)(xi). - Reference is made to section 2(zh) of the Industrial Relations Code, 2020, to support the argument that non-renewal of a contract is distinct from retrenchment. - AO directed to delete the additions.
Characterization of receipt - Compensation receipt on termination of contract - Addition under Section 28(ii)(e) - The Tribunal differentiates between termination and non-renewal of a contract and argues that the compensation received due to non-renewal should not be treated as termination under Section 28(ii)(e) or Section 56(2)(xi). - Reference is made to section 2(zh) of the Industrial Relations Code, 2020, to support the argument that non-renewal of a contract is distinct from retrenchment. - AO directed to delete the additions.
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