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...
Additions under ss. 69A and 69B were examined on whether they could rest primarily on a statement recorded u/s 132(4) and generalized references to digital material. It was held that, absent identification of any specific incriminating seized document and without corroborative evidence of unexplained money or investment, the deeming provisions could not be invoked; the seized cash/jewellery already stood offered as business income from land-deal activity and was taxable u/s 28, not u/ss. 69A/69B r/w s. 115BBE, so these additions were deleted. On brokerage, addition was sustained where there was clear admission of receipt from both sides, but deleted for another transaction where no admission existed and the AO's 1% estimate lacked documentary/third-party support; CIT(A)'s order was affirmed. - ITAT
Additions under ss. 69A and 69B were examined on whether they could rest primarily on a statement recorded u/s 132(4) and generalized references to digital material. It was held that, absent identification of any specific incriminating seized document and without corroborative evidence of unexplained money or investment, the deeming provisions could not be invoked; the seized cash/jewellery already stood offered as business income from land-deal activity and was taxable u/s 28, not u/ss. 69A/69B r/w s. 115BBE, so these additions were deleted. On brokerage, addition was sustained where there was clear admission of receipt from both sides, but deleted for another transaction where no admission existed and the AO's 1% estimate lacked documentary/third-party support; CIT(A)'s order was affirmed. - ITAT
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