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...
Assessee held shares as stock-in-trade for trading purposes, not to earn dividend income. HC held provisions of Section 14A disallowing expenses relatable to exempt income inapplicable as no exempt income accrued. Where shares held as stock-in-trade, earning dividend immaterial; purpose is to trade by selling when price rises to earn profits. Situation differs from holding shares to retain control over investee company and intentionally earning dividend. Decided against revenue.
Assessee held shares as stock-in-trade for trading purposes, not to earn dividend income. HC held provisions of Section 14A disallowing expenses relatable to exempt income inapplicable as no exempt income accrued. Where shares held as stock-in-trade, earning dividend immaterial; purpose is to trade by selling when price rises to earn profits. Situation differs from holding shares to retain control over investee company and intentionally earning dividend. Decided against revenue.
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