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...
Jurisdiction assumed by DCIT not challenged within stipulated period, hence cannot be questioned now. Addition u/s 68 not sustainable as summary of receipts discloses names, addresses, and telephone numbers of donors with specific directions for contributions. Matter remanded to verify authenticity of summary receipts and copies of receipts issued. Notice u/s 143(2) issued prior to intimation u/s 143(1) valid as per Supreme Court ruling in CIT vs. Gujarat Electricity Board case, where processing u/s 143(1) subsequent to notice u/s 143(2) does not invalidate the notice.
Jurisdiction assumed by DCIT not challenged within stipulated period, hence cannot be questioned now. Addition u/s 68 not sustainable as summary of receipts discloses names, addresses, and telephone numbers of donors with specific directions for contributions. Matter remanded to verify authenticity of summary receipts and copies of receipts issued. Notice u/s 143(2) issued prior to intimation u/s 143(1) valid as per Supreme Court ruling in CIT vs. Gujarat Electricity Board case, where processing u/s 143(1) subsequent to notice u/s 143(2) does not invalidate the notice.
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