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...
Impugned order setting aside claim for interest u/s 244A(2) was incorrect. Court held delay attributable to assessee must be excluded for computing interest period, but Department failed to exercise due diligence causing loss to assessee. No straight-jacket formula applies; each case warrants consideration based on facts. Order remanded to Department to reconsider interest claim from date of filing Revision Petition till payment date at 6% per annum after adjusting refund already granted.
Impugned order setting aside claim for interest u/s 244A(2) was incorrect. Court held delay attributable to assessee must be excluded for computing interest period, but Department failed to exercise due diligence causing loss to assessee. No straight-jacket formula applies; each case warrants consideration based on facts. Order remanded to Department to reconsider interest claim from date of filing Revision Petition till payment date at 6% per annum after adjusting refund already granted.
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