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 issues including best judgment assessment u/s 143(3) and eligibility for exemption u/ss 11/12. The Tribunal noted the lack of documentary evidence and non-compliance by the assessee despite notices. The assessee raised fresh grounds on the applicability of section 12AA and cited CBDT Circular No. 01/2015 regarding the retrospective operation of the first proviso to section 12A(2). The Tribunal found the AO did not consider this issue during assessment and remanded the matter for a fresh assessment. The appeal of the assessee was allowed for statistical purposes.
The Appellate Tribunal addressed issues including best judgment assessment u/s 143(3) and eligibility for exemption u/ss 11/12. The Tribunal noted the lack of documentary evidence and non-compliance by the assessee despite notices. The assessee raised fresh grounds on the applicability of section 12AA and cited CBDT Circular No. 01/2015 regarding the retrospective operation of the first proviso to section 12A(2). The Tribunal found the AO did not consider this issue during assessment and remanded the matter for a fresh assessment. The appeal of the assessee was allowed for statistical purposes.
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