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 allowed the assessee's appeal, finding that the statutory notice under section 142(1) was not sent to the registered email addresses as defined in Explanation (t) to section 144B. The tribunal determined the assessee's explanation constituted "reasonable cause" under section 273B, thereby directing deletion of the penalty levied under section 271(1)(b). The tribunal recognized the procedural non-compliance by the revenue department in serving the notice, which effectively invalidated the penalty proceedings against the assessee.
ITAT allowed the assessee's appeal, finding that the statutory notice under section 142(1) was not sent to the registered email addresses as defined in Explanation (t) to section 144B. The tribunal determined the assessee's explanation constituted "reasonable cause" under section 273B, thereby directing deletion of the penalty levied under section 271(1)(b). The tribunal recognized the procedural non-compliance by the revenue department in serving the notice, which effectively invalidated the penalty proceedings against the assessee.
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