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 appeal: the Revenue's addition under s.50C was rejected and the third proviso's 10% tolerance margin applies retrospectively, disallowing the technical argument that FMV determined by the DVO (versus stamp duty value) justified an uplift; the assessee's challenge on this ground succeeds. Separately, the Tribunal held the assessee entitled to deduction under s.54EC because actual reinvestment and return filing under s.139(1) were established; the claim may be recognized beyond the figures in the original computation as not barred by statute. Net result: impugned s.50C addition set aside and s.54EC relief allowed in favour of the assessee.
ITAT allowed the appeal: the Revenue's addition under s.50C was rejected and the third proviso's 10% tolerance margin applies retrospectively, disallowing the technical argument that FMV determined by the DVO (versus stamp duty value) justified an uplift; the assessee's challenge on this ground succeeds. Separately, the Tribunal held the assessee entitled to deduction under s.54EC because actual reinvestment and return filing under s.139(1) were established; the claim may be recognized beyond the figures in the original computation as not barred by statute. Net result: impugned s.50C addition set aside and s.54EC relief allowed in favour of the assessee.
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