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 ITAT ruled on two issues: 1. Disallowance of Business Promotion Expenses: AO disallowed expenses for a get-together, citing lack of proof of business purpose. CIT(A) upheld, but ITAT found the expenses legitimate due to revenue from operations, accepted expenses, and TDS payment to caterer. AO's disallowance was deemed incorrect. 2. Cessation of Liability u/s 41(1): AO added outstanding professional fees as income u/s 41(1) for being unpaid over 3 years. ITAT disagreed, noting the liability in financial statements indicates intent to settle. Addition was deemed incorrect, and AO was directed to delete it. Assessee's appeal was allowed.
The ITAT ruled on two issues: 1. Disallowance of Business Promotion Expenses: AO disallowed expenses for a get-together, citing lack of proof of business purpose. CIT(A) upheld, but ITAT found the expenses legitimate due to revenue from operations, accepted expenses, and TDS payment to caterer. AO's disallowance was deemed incorrect. 2. Cessation of Liability u/s 41(1): AO added outstanding professional fees as income u/s 41(1) for being unpaid over 3 years. ITAT disagreed, noting the liability in financial statements indicates intent to settle. Addition was deemed incorrect, and AO was directed to delete it. Assessee's appeal was allowed.
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