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 adjudicated a penalty case under Section 272A(2)(e) regarding non-filing of income tax return. The tribunal directed the CIT(Appeals) to re-examine the assessee's claim of exemption under Section 10(23C)(iiiad), which potentially absolves them from mandatory return filing. The tribunal noted the assessee's failure to provide substantive reasons for non-compliance and insufficient explanation for the delay. The matter was remanded for de novo adjudication, requiring the assessee to present comprehensive evidence and rationale for challenging the proposed penalty. The CIT(Appeals) is mandated to conduct a fresh merit-based assessment of the penalty proceedings.
ITAT adjudicated a penalty case under Section 272A(2)(e) regarding non-filing of income tax return. The tribunal directed the CIT(Appeals) to re-examine the assessee's claim of exemption under Section 10(23C)(iiiad), which potentially absolves them from mandatory return filing. The tribunal noted the assessee's failure to provide substantive reasons for non-compliance and insufficient explanation for the delay. The matter was remanded for de novo adjudication, requiring the assessee to present comprehensive evidence and rationale for challenging the proposed penalty. The CIT(Appeals) is mandated to conduct a fresh merit-based assessment of the penalty proceedings.
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