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...
Levy of penalty u/s 272A(1)(d) - Non compliance to the notice(s) issued during the course of assessment proceedings - The ITAT noted that the assessee did respond to notices during assessment proceedings, indicating compliance. - Notices issued on a public holiday with short response times (i.e. two hours) were deemed unreasonable by the Tribunal. - The Tribunal found no justifiable basis for the penalty under section 272A(1)(d) of the Act. - Consequently, the penalty was directed to be deleted, and the appeal of the assessee was allowed.
Levy of penalty u/s 272A(1)(d) - Non compliance to the notice(s) issued during the course of assessment proceedings - The ITAT noted that the assessee did respond to notices during assessment proceedings, indicating compliance. - Notices issued on a public holiday with short response times (i.e. two hours) were deemed unreasonable by the Tribunal. - The Tribunal found no justifiable basis for the penalty under section 272A(1)(d) of the Act. - Consequently, the penalty was directed to be deleted, and the appeal of the assessee was allowed.
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