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 affirmed that once Form No. 10EE is validly furnished for a prior assessment year, the option thereby exercised under Rule 21AAA(1) continues to apply to subsequent years and need not be filed afresh annually. Consequently, denial of relief under section 89A of the Income-tax Act on the sole ground that Form No. 10EE was not refiled in the current year is unsustainable. The Tribunal held the filing requirement to be procedural and constative under Rule 21AAA(6), and directed that relief under section 89A be allowed to the assessee, overturning the contrary finding of the lower authority.
ITAT affirmed that once Form No. 10EE is validly furnished for a prior assessment year, the option thereby exercised under Rule 21AAA(1) continues to apply to subsequent years and need not be filed afresh annually. Consequently, denial of relief under section 89A of the Income-tax Act on the sole ground that Form No. 10EE was not refiled in the current year is unsustainable. The Tribunal held the filing requirement to be procedural and constative under Rule 21AAA(6), and directed that relief under section 89A be allowed to the assessee, overturning the contrary finding of the lower authority.
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