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...
Assessment u/s 153A - Addition of undisclosed income - Contract between assessee and non-resident entity for sharing profits from supply of currency paper to RBI - No incriminating material found during search and seizure - Agreement terminated in 2012 and assessee became non-resident from 2015-16 onwards - Receipts from foreign entities pertain to later years - Revenue unable to establish link between payments and terminated agreement - ITAT rightly deleted additions based on lack of incriminating evidence - No substantial questions of law arise.
Assessment u/s 153A - Addition of undisclosed income - Contract between assessee and non-resident entity for sharing profits from supply of currency paper to RBI - No incriminating material found during search and seizure - Agreement terminated in 2012 and assessee became non-resident from 2015-16 onwards - Receipts from foreign entities pertain to later years - Revenue unable to establish link between payments and terminated agreement - ITAT rightly deleted additions based on lack of incriminating evidence - No substantial questions of law arise.
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