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...
Charitable society received cash credits from a non-resident individual, offered as taxable income. AO doubted credibility of donor based on his wife's statement about monthly expenses. ITAT held donor's non-taxability in separate assessment u/ss 153C and 144 lends credence to transaction. Society's charitable nature, public utility works undisputed. Mere suspicion based on donor's association insufficient to treat him as conduit. Wife's unawareness about donations renders reliance on her statement unjustified. Lack of corroborative evidence from Gupta brothers' search precludes treating donor as conduit. Affidavit possessed by assessee supports donation. Revenue's grounds rejected, decided in assessee's favor.
Charitable society received cash credits from a non-resident individual, offered as taxable income. AO doubted credibility of donor based on his wife's statement about monthly expenses. ITAT held donor's non-taxability in separate assessment u/ss 153C and 144 lends credence to transaction. Society's charitable nature, public utility works undisputed. Mere suspicion based on donor's association insufficient to treat him as conduit. Wife's unawareness about donations renders reliance on her statement unjustified. Lack of corroborative evidence from Gupta brothers' search precludes treating donor as conduit. Affidavit possessed by assessee supports donation. Revenue's grounds rejected, decided in assessee's favor.
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