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 ruled against reopening of assessment concerning alleged unaccounted cash loans of Rs.11.05 crore. AO's action based solely on Investigation Wing's information about cash loans through a broker was deemed insufficient for establishing income escapement. The mere receipt of loans cannot constitute income without substantiating evidence of sham transactions. AO failed to discharge the burden of proof after assessee's denial, presenting no corroborating evidence of actual lenders or cash possession. No valuable assets or undisclosed income were discovered with the assessee. The tribunal invalidated the assessment reopening due to lack of tangible material demonstrating income concealment beyond mere information about loan transactions.
ITAT ruled against reopening of assessment concerning alleged unaccounted cash loans of Rs.11.05 crore. AO's action based solely on Investigation Wing's information about cash loans through a broker was deemed insufficient for establishing income escapement. The mere receipt of loans cannot constitute income without substantiating evidence of sham transactions. AO failed to discharge the burden of proof after assessee's denial, presenting no corroborating evidence of actual lenders or cash possession. No valuable assets or undisclosed income were discovered with the assessee. The tribunal invalidated the assessment reopening due to lack of tangible material demonstrating income concealment beyond mere information about loan transactions.
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