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 on multiple issues in a tax assessment case. The Tribunal allowed 60% expenditure deduction against unaccounted cash receipts from spent solvents/scrap sales, following precedent from MSN Pharmachem Private Limited case. The court upheld AO's jurisdiction for notice under Section 153A, finding sufficient evidence of undisclosed income exceeding fifty lakh rupees. The Tribunal validated the assessment of 'on-money' payments for land purchase at Bibinagar, confirming that evidence from related party searches was admissible. However, the addition of deemed dividend under Section 2(22)(e) was set aside, directing AO to delete the addition following MSN Pharmachem precedent. The notice under Section 153A and subsequent assessment order were deemed valid under Section 153A(1).
ITAT ruled on multiple issues in a tax assessment case. The Tribunal allowed 60% expenditure deduction against unaccounted cash receipts from spent solvents/scrap sales, following precedent from MSN Pharmachem Private Limited case. The court upheld AO's jurisdiction for notice under Section 153A, finding sufficient evidence of undisclosed income exceeding fifty lakh rupees. The Tribunal validated the assessment of 'on-money' payments for land purchase at Bibinagar, confirming that evidence from related party searches was admissible. However, the addition of deemed dividend under Section 2(22)(e) was set aside, directing AO to delete the addition following MSN Pharmachem precedent. The notice under Section 153A and subsequent assessment order were deemed valid under Section 153A(1).
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