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...
AO proceeded with best judgment assessment u/s 144 making addition u/s 68 for unexplained cash deposit. CIT(A) upheld penalty u/s 272A(1)(d) for non-compliance with notices u/s 142(1), 143(2). ITAT held non-compliance wasn't willful, but due to negligence of authorized representative beyond assessee's control. Show-cause notice by AO u/s 274 r.w.s. 272A(1)(d) lacked specificity, erroneously invoking inapplicable provision. Assessee demonstrated reasonable cause u/s 273B through affidavits explaining default wasn't mala fide. Initial compliance showed intention to cooperate. Penalty unsustainable. Decided in assessee's favor.
AO proceeded with best judgment assessment u/s 144 making addition u/s 68 for unexplained cash deposit. CIT(A) upheld penalty u/s 272A(1)(d) for non-compliance with notices u/s 142(1), 143(2). ITAT held non-compliance wasn't willful, but due to negligence of authorized representative beyond assessee's control. Show-cause notice by AO u/s 274 r.w.s. 272A(1)(d) lacked specificity, erroneously invoking inapplicable provision. Assessee demonstrated reasonable cause u/s 273B through affidavits explaining default wasn't mala fide. Initial compliance showed intention to cooperate. Penalty unsustainable. Decided in assessee's favor.
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