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 Appellate Tribunal addressed multiple issues in the case. Firstly, it ruled that disallowance u/s 40A(2)(b) can only be made in relation to "related parties," not unrelated ones. The disallowance of interest expenses to unrelated parties was deemed incorrect. Secondly, the Tribunal found that the assessing officer's adoption of 11% as the "fair market value" of interest lacked proper justification and comparable cases. Thirdly, the addition u/s 68 for unsecured loans lacked thorough inquiry by the assessing officer, and the documentary evidence provided by the assessee was considered adequate. The Tribunal decided in favor of the assessee on all these grounds.
The Appellate Tribunal addressed multiple issues in the case. Firstly, it ruled that disallowance u/s 40A(2)(b) can only be made in relation to "related parties," not unrelated ones. The disallowance of interest expenses to unrelated parties was deemed incorrect. Secondly, the Tribunal found that the assessing officer's adoption of 11% as the "fair market value" of interest lacked proper justification and comparable cases. Thirdly, the addition u/s 68 for unsecured loans lacked thorough inquiry by the assessing officer, and the documentary evidence provided by the assessee was considered adequate. The Tribunal decided in favor of the assessee on all these grounds.
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