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...
The case involved denial of exemption u/s 11 due to late filing of return. The department argued return must be filed u/s 139(1) to claim exemption u/s 11. An amendment clarified return should be filed within time u/s 139. ITAT held the amendment excluded updated returns u/s 139(8) and all other returns were eligible. Assessee filed within time u/s 139(4), so exemption u/s 11 should not be denied. Circular clarified return must be filed within time u/s 139. ITAT relied on precedent that if return is filed before due date u/s 139(4), exemption u/s 11 cannot be denied. Department was directed to allow exemption u/s 11.
The case involved denial of exemption u/s 11 due to late filing of return. The department argued return must be filed u/s 139(1) to claim exemption u/s 11. An amendment clarified return should be filed within time u/s 139. ITAT held the amendment excluded updated returns u/s 139(8) and all other returns were eligible. Assessee filed within time u/s 139(4), so exemption u/s 11 should not be denied. Circular clarified return must be filed within time u/s 139. ITAT relied on precedent that if return is filed before due date u/s 139(4), exemption u/s 11 cannot be denied. Department was directed to allow exemption u/s 11.
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