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 allowed the assessee's appeal and deleted the additions under s. 69. The Tribunal held that the impugned property's total purchase consideration was Rs. 45,47,701, of which the assessee, as 50% co-owner, only bore Rs. 22,73,850. The assessee satisfactorily explained Rs. 22,00,000 of that share; the remaining Rs. 73,850 was plausibly attributable to cash-in-hand disclosed in the return relating to dairy income and could have been called for explanation by the AO. The AO's blanket addition of the entire investment was therefore found unjustified and set aside.
ITAT allowed the assessee's appeal and deleted the additions under s. 69. The Tribunal held that the impugned property's total purchase consideration was Rs. 45,47,701, of which the assessee, as 50% co-owner, only bore Rs. 22,73,850. The assessee satisfactorily explained Rs. 22,00,000 of that share; the remaining Rs. 73,850 was plausibly attributable to cash-in-hand disclosed in the return relating to dairy income and could have been called for explanation by the AO. The AO's blanket addition of the entire investment was therefore found unjustified and set aside.
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