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 dismissed Revenue's appeal against CIT(A)'s order deleting additions under s.68 for alleged bogus share capital and unsecured loans. The assessee successfully demonstrated identity, creditworthiness, and transaction genuineness by providing shareholder confirmations, bank statements, and ITRs. AO's additions were rejected as based merely on doubt without contradictory evidence. CIT(A)'s partial allowance of s.14A disallowance was upheld, limiting it to investments yielding exempt income. ITAT affirmed CIT(A)'s authority to admit additional evidence without mandatory AO remand under s.250(4) and Rule 46A(4). The related interest expenses on unsecured loans were consequently allowed, and corresponding adjustments to WIP were permitted.
ITAT dismissed Revenue's appeal against CIT(A)'s order deleting additions under s.68 for alleged bogus share capital and unsecured loans. The assessee successfully demonstrated identity, creditworthiness, and transaction genuineness by providing shareholder confirmations, bank statements, and ITRs. AO's additions were rejected as based merely on doubt without contradictory evidence. CIT(A)'s partial allowance of s.14A disallowance was upheld, limiting it to investments yielding exempt income. ITAT affirmed CIT(A)'s authority to admit additional evidence without mandatory AO remand under s.250(4) and Rule 46A(4). The related interest expenses on unsecured loans were consequently allowed, and corresponding adjustments to WIP were permitted.
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