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 held that the addition under Section 69C was unsustainable due to procedural impropriety. The AO's reliance solely on unverified statements, without providing cross-examination opportunities, violated principles of natural justice. The tribunal found no corroborative evidence to substantiate the allegations of cash transactions. The seized materials were deemed insufficient as primary direct evidence. The assessment order was consequently set aside, with the tribunal ruling in favor of the assessee and against the revenue's claims.
ITAT held that the addition under Section 69C was unsustainable due to procedural impropriety. The AO's reliance solely on unverified statements, without providing cross-examination opportunities, violated principles of natural justice. The tribunal found no corroborative evidence to substantiate the allegations of cash transactions. The seized materials were deemed insufficient as primary direct evidence. The assessment order was consequently set aside, with the tribunal ruling in favor of the assessee and against the revenue's claims.
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