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 CIT(E)'s refusal to grant registration under s.12AB and remitted the matter to the file of the CIT(E) for fresh adjudication. The Tribunal held that the CIT(E)'s conclusion-that the s.8 company merely supplied personnel to a CSR-donor in exchange for contributions and therefore its activities fell outside s.2(15)-was based on suspicion and surmise without evidentiary foundation. The ITAT noted the appellant/assessee had produced project reports and supporting documents showing charitable works (village road and school building projects), and directed the CIT(E) to reassess the application on the basis of the evidentiary record.
The ITAT set aside the CIT(E)'s refusal to grant registration under s.12AB and remitted the matter to the file of the CIT(E) for fresh adjudication. The Tribunal held that the CIT(E)'s conclusion-that the s.8 company merely supplied personnel to a CSR-donor in exchange for contributions and therefore its activities fell outside s.2(15)-was based on suspicion and surmise without evidentiary foundation. The ITAT noted the appellant/assessee had produced project reports and supporting documents showing charitable works (village road and school building projects), and directed the CIT(E) to reassess the application on the basis of the evidentiary record.
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