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) - defective notice u/s 274 - The Tribunal emphasized the necessity for such notices to clearly delineate the charge against the assessee, allowing them to prepare an adequate defense. It found that the AO's notices were deficient in this respect, not specifying whether the penalties were for "concealment of income" or "furnishing of inaccurate particulars of income." This ambiguity, the Tribunal held, constituted a failure to meet legal standards, rendering the penalties unsustainable.
Penalty u/s 271(1)(c) - defective notice u/s 274 - The Tribunal emphasized the necessity for such notices to clearly delineate the charge against the assessee, allowing them to prepare an adequate defense. It found that the AO's notices were deficient in this respect, not specifying whether the penalties were for "concealment of income" or "furnishing of inaccurate particulars of income." This ambiguity, the Tribunal held, constituted a failure to meet legal standards, rendering the penalties unsustainable.
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