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...
The ITAT set aside the penalty under section 271(1)(c) imposed for disallowing deduction under section 80P relating to interest on staff advances and miscellaneous income. The tribunal found that the assessee had accurately disclosed the relevant particulars in the return, computation, and financial statements, including the disputed treatment of interest on staff advances. The AO's conclusion of concealment or furnishing inaccurate particulars was unfounded as the interest was reflected in the Profit & Loss account. Following established precedent, the ITAT held that mere erroneous claims do not constitute inaccurate particulars absent proof of false or incorrect information. Consequently, the penalty was quashed, and the appeal was allowed in favor of the assessee.
The ITAT set aside the penalty under section 271(1)(c) imposed for disallowing deduction under section 80P relating to interest on staff advances and miscellaneous income. The tribunal found that the assessee had accurately disclosed the relevant particulars in the return, computation, and financial statements, including the disputed treatment of interest on staff advances. The AO's conclusion of concealment or furnishing inaccurate particulars was unfounded as the interest was reflected in the Profit & Loss account. Following established precedent, the ITAT held that mere erroneous claims do not constitute inaccurate particulars absent proof of false or incorrect information. Consequently, the penalty was quashed, and the appeal was allowed in favor of the assessee.
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