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 the CIT(A)'s order deleting penalty u/s 271(1)(c) against the assessee. The tribunal found the depreciation claim was a clerical error without malafide intention to evade taxes. The error was rectified in subsequent assessment year and did not impact tax liability. Relying on Supreme Court precedent, the tribunal concluded that a non-sustainable claim does not automatically constitute furnishing inaccurate income particulars. Consequently, the penalty was deleted, affirming the lower appellate authority's reasoning that the assessee's action did not warrant punitive measures.
ITAT upheld the CIT(A)'s order deleting penalty u/s 271(1)(c) against the assessee. The tribunal found the depreciation claim was a clerical error without malafide intention to evade taxes. The error was rectified in subsequent assessment year and did not impact tax liability. Relying on Supreme Court precedent, the tribunal concluded that a non-sustainable claim does not automatically constitute furnishing inaccurate income particulars. Consequently, the penalty was deleted, affirming the lower appellate authority's reasoning that the assessee's action did not warrant punitive measures.
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