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...
ITAT upheld AO's denial of deduction u/s 10A due to defective Form 56F filing. The form, signed by "Deloitte Haskins and Sells," failed to meet statutory requirements as it lacked proper certification by an "Accountant" as defined u/s 288(2). The tribunal emphasized that certification must be provided by a Chartered Accountant qualifying u/s 2(1)(b) of the Chartered Accountants Act, 1949. The assessee's inability to demonstrate that the signing entity met the definition of an "Accountant" u/s 10A(5) rendered the form defective. CIT(A)'s favorable ruling was reversed, and deduction claim was rejected.
ITAT upheld AO's denial of deduction u/s 10A due to defective Form 56F filing. The form, signed by "Deloitte Haskins and Sells," failed to meet statutory requirements as it lacked proper certification by an "Accountant" as defined u/s 288(2). The tribunal emphasized that certification must be provided by a Chartered Accountant qualifying u/s 2(1)(b) of the Chartered Accountants Act, 1949. The assessee's inability to demonstrate that the signing entity met the definition of an "Accountant" u/s 10A(5) rendered the form defective. CIT(A)'s favorable ruling was reversed, and deduction claim was rejected.
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