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...
Disallowance under s.14A was unsustainable because the AO enhanced the disallowance despite the assessee's detailed working, without examining the accounts to record the mandatory dissatisfaction with the assessee's computation; deletion of the additional disallowance was upheld. Addition of the s.14A amount while computing book profit under s.115JB was impermissible in law, consistent with binding precedent that such disallowance cannot be mechanically added back; the MAT adjustment was deleted. Deduction under s.35(2AB) could not be denied merely for non-availability of DSIR Form 3CL during assessment when the form was subsequently issued and covered the relevant expenditure; the deduction was allowed. - ITAT
Disallowance under s.14A was unsustainable because the AO enhanced the disallowance despite the assessee's detailed working, without examining the accounts to record the mandatory dissatisfaction with the assessee's computation; deletion of the additional disallowance was upheld. Addition of the s.14A amount while computing book profit under s.115JB was impermissible in law, consistent with binding precedent that such disallowance cannot be mechanically added back; the MAT adjustment was deleted. Deduction under s.35(2AB) could not be denied merely for non-availability of DSIR Form 3CL during assessment when the form was subsequently issued and covered the relevant expenditure; the deduction was allowed. - ITAT
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