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 partial addition of Rs. 2,25,000 as unexplained creditor under Section 68, while dismissing Revenue's challenge to remaining loan transactions. The tribunal found the assessee successfully established three key ingredients: identity, creditworthiness, and genuineness of transactions from the lender. Despite absence of ITR, the tribunal accepted the loan's source and routing, relying on documentary evidence including account confirmations and bank records. Consistent with precedential rulings, the tribunal concluded no unaccounted income was demonstrated, thereby partially allowing the assessee's appeal and confirming only a limited portion of the disputed amount.
ITAT upheld partial addition of Rs. 2,25,000 as unexplained creditor under Section 68, while dismissing Revenue's challenge to remaining loan transactions. The tribunal found the assessee successfully established three key ingredients: identity, creditworthiness, and genuineness of transactions from the lender. Despite absence of ITR, the tribunal accepted the loan's source and routing, relying on documentary evidence including account confirmations and bank records. Consistent with precedential rulings, the tribunal concluded no unaccounted income was demonstrated, thereby partially allowing the assessee's appeal and confirming only a limited portion of the disputed amount.
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