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 upheld additions under Section 68 for unexplained share application money from two companies. The tribunal confirmed the Assessing Officer's (AO) order, finding the assessee failed to establish the creditworthiness and identity of share applicants. The initial burden of proving transaction genuineness rests with the assessee. Additionally, the tribunal disallowed loss on sale of fixed assets, ruling such loss is not an allowable expenditure under Section 37. The AO's disallowance was sustained, and grounds of appeal were dismissed, affirming the lower authorities' findings on both share application money and fixed asset sale.
ITAT upheld additions under Section 68 for unexplained share application money from two companies. The tribunal confirmed the Assessing Officer's (AO) order, finding the assessee failed to establish the creditworthiness and identity of share applicants. The initial burden of proving transaction genuineness rests with the assessee. Additionally, the tribunal disallowed loss on sale of fixed assets, ruling such loss is not an allowable expenditure under Section 37. The AO's disallowance was sustained, and grounds of appeal were dismissed, affirming the lower authorities' findings on both share application money and fixed asset sale.
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