Tax appeal allowed: AO exceeded s.144C DRP mandate by introducing new findings and recharacterising non-resident receipts as permanent establishment i...
Anonymized petitioner gets partial relief: bank guarantee quashed, PVC-coated fabric released under reduced conditions while valuation proceedings con...
ITAT dismissed the Revenue's appeal and upheld the assessee's stance, setting aside the addition under s.69. The Tribunal found the impugned WhatsApp screenshots unauthenticated, lacking any official signature or section 65B(4) certificate, and noted absence of the source device; thus the digital excerpts were inadmissible and susceptible to fabrication. The AO failed to obtain corroboration from Registration/Stamp Duty authorities, ignored the government-fixed stamp duty rate, and produced no comparable market evidence; the contested market-value computation appeared conjectural. No independent evidence of unexplained cash receipts was established, rendering the addition speculative and unsustainable.
ITAT dismissed the Revenue's appeal and upheld the assessee's stance, setting aside the addition under s.69. The Tribunal found the impugned WhatsApp screenshots unauthenticated, lacking any official signature or section 65B(4) certificate, and noted absence of the source device; thus the digital excerpts were inadmissible and susceptible to fabrication. The AO failed to obtain corroboration from Registration/Stamp Duty authorities, ignored the government-fixed stamp duty rate, and produced no comparable market evidence; the contested market-value computation appeared conjectural. No independent evidence of unexplained cash receipts was established, rendering the addition speculative and unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
