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 order under s.271(1)(c) r.w.s.274 insofar as it was founded on a defective show-cause notice that failed to specify the precise charge-whether concealment of particulars of income or furnishing inaccurate particulars-thereby depriving the assessee of the ability to frame an effective defence. The Tribunal found the notice to be a standard, mechanistic document issued without application of mind, and held that penalty imposition in such circumstances is invalid. Consequently the penalty levied was quashed and the appeal allowed in favour of the assessee.
The ITAT set aside the penalty order under s.271(1)(c) r.w.s.274 insofar as it was founded on a defective show-cause notice that failed to specify the precise charge-whether concealment of particulars of income or furnishing inaccurate particulars-thereby depriving the assessee of the ability to frame an effective defence. The Tribunal found the notice to be a standard, mechanistic document issued without application of mind, and held that penalty imposition in such circumstances is invalid. Consequently the penalty levied was quashed and the appeal allowed in favour of the assessee.
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