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...
Addition u/s 68 - unexplained cash credit - Onus to prove - The High court noted that the assessee had provided sufficient evidence, including bank statements, cash-flow statements, and other relevant documents, to support their claim regarding the source of cash deposits and capital introduced in the partnership firm. - It was observed that the Assessing Officer did not provide any adverse findings or reasoning to rebut the evidence submitted by the assessee. The court emphasized that evidence cannot be disregarded based on mere surmise and conjecture. - The court allowed the appeal of the assessee and ordered the deletion of the addition.
Addition u/s 68 - unexplained cash credit - Onus to prove - The High court noted that the assessee had provided sufficient evidence, including bank statements, cash-flow statements, and other relevant documents, to support their claim regarding the source of cash deposits and capital introduced in the partnership firm. - It was observed that the Assessing Officer did not provide any adverse findings or reasoning to rebut the evidence submitted by the assessee. The court emphasized that evidence cannot be disregarded based on mere surmise and conjecture. - The court allowed the appeal of the assessee and ordered the deletion of the addition.
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