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 upheld the CIT(A)'s deletion of the addition of Rs. 3,70,540/- relating to share capital subscription, finding the assessee had adequately substantiated the genuineness of the transaction. Regarding the disallowance under section 40A(3) for payments to related parties, the Tribunal affirmed the partial disallowance of Rs. 10,000/- for staff welfare expenses due to lack of evidence, while granting relief of Rs. 5,49,318/- on other payments. The addition on account of unsecured loans was also deleted, as the unsecured loans represented reclassification of dividend payables to shareholders with no fresh credit introduced, and no material indicated concealment. Consequently, the Revenue's appeal was dismissed in its entirety.
The ITAT upheld the CIT(A)'s deletion of the addition of Rs. 3,70,540/- relating to share capital subscription, finding the assessee had adequately substantiated the genuineness of the transaction. Regarding the disallowance under section 40A(3) for payments to related parties, the Tribunal affirmed the partial disallowance of Rs. 10,000/- for staff welfare expenses due to lack of evidence, while granting relief of Rs. 5,49,318/- on other payments. The addition on account of unsecured loans was also deleted, as the unsecured loans represented reclassification of dividend payables to shareholders with no fresh credit introduced, and no material indicated concealment. Consequently, the Revenue's appeal was dismissed in its entirety.
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