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...
Deduction u/s 35(1)(ii) disallowed by AO based on Investigation Wing's report alleging bogus donations receipts issued by institutions. ITAT held AO did not make independent inquiry to prove applicability of Investigation Wing's view to assessee. No material brought to disprove assessee's evidence regarding donations paid. No proof of cheque amount being ploughed back as cash to assessee. Subsequent withdrawal of recognition u/s 35(1)(ii) not a bar for allowing deduction for earlier donations. Assessee's claim u/s 35(1)(ii) allowed for both years. Assessee appeal allowed.
Deduction u/s 35(1)(ii) disallowed by AO based on Investigation Wing's report alleging bogus donations receipts issued by institutions. ITAT held AO did not make independent inquiry to prove applicability of Investigation Wing's view to assessee. No material brought to disprove assessee's evidence regarding donations paid. No proof of cheque amount being ploughed back as cash to assessee. Subsequent withdrawal of recognition u/s 35(1)(ii) not a bar for allowing deduction for earlier donations. Assessee's claim u/s 35(1)(ii) allowed for both years. Assessee appeal allowed.
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