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 on the assessee for alleged concealment and furnishing of inaccurate income particulars. The assessee's claim of invoking the "owelty" principle to characterize received amounts as non-taxable was previously rejected in quantum proceedings; however, this does not automatically justify penalty imposition. The Tribunal held that penalty proceedings run parallel to assessment and mere disallowance or addition does not warrant penalty without deliberate concealment. Consequently, the impugned penalty was deleted, and the assessee's appeal was allowed.
The ITAT set aside the penalty under section 271(1)(c) imposed on the assessee for alleged concealment and furnishing of inaccurate income particulars. The assessee's claim of invoking the "owelty" principle to characterize received amounts as non-taxable was previously rejected in quantum proceedings; however, this does not automatically justify penalty imposition. The Tribunal held that penalty proceedings run parallel to assessment and mere disallowance or addition does not warrant penalty without deliberate concealment. Consequently, the impugned penalty was deleted, and the assessee's appeal was allowed.
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