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...
Issue was whether CPC could, in an intimation under s.143(1)(a)(ii), treat a belated return as an "incorrect claim" and deny deduction under s.80P for the relevant AY. Although coordinate benches had held that belated filing is not covered by the Explanation to "incorrect claim" and noted that a specific adjustment for such disallowance was introduced only by s.143(1)(a)(v) w.e.f. 01.04.2021, the Tribunal followed the binding precedent of the jurisdictional HC, which had upheld denial of s.80P in s.143(1)(a)(ii) where the return was not filed within s.139(1) due date; hence the intimation was sustained and the appeal was dismissed. - ITAT
Issue was whether CPC could, in an intimation under s.143(1)(a)(ii), treat a belated return as an "incorrect claim" and deny deduction under s.80P for the relevant AY. Although coordinate benches had held that belated filing is not covered by the Explanation to "incorrect claim" and noted that a specific adjustment for such disallowance was introduced only by s.143(1)(a)(v) w.e.f. 01.04.2021, the Tribunal followed the binding precedent of the jurisdictional HC, which had upheld denial of s.80P in s.143(1)(a)(ii) where the return was not filed within s.139(1) due date; hence the intimation was sustained and the appeal was dismissed. - ITAT
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