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 - Applicability of the substituted rule for imposition of penalty - The Supreme Court sided with the appellant, holding that the substituted rule from 2011 should apply to the proceedings. The Court found that the purpose of the amendment to the penalty rules was to achieve a proper balance between the offence and the penalty, reflecting a shift toward a more equitable approach in the imposition of penalties. - The Court clarified that once a rule is substituted, the old rule ceases to exist entirely and should not be applied to ongoing or future proceedings.
Levy of penalty - Applicability of the substituted rule for imposition of penalty - The Supreme Court sided with the appellant, holding that the substituted rule from 2011 should apply to the proceedings. The Court found that the purpose of the amendment to the penalty rules was to achieve a proper balance between the offence and the penalty, reflecting a shift toward a more equitable approach in the imposition of penalties. - The Court clarified that once a rule is substituted, the old rule ceases to exist entirely and should not be applied to ongoing or future proceedings.
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