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...
Whether seized documents constituted "incriminating material" to sustain an addition under section 68: Tribunal found the assessee's books and financials consistently showed investment/trading in shares, no evidence of physical movement of goods, and no AO finding that seized Tally data were parallel books; search material related to other group entities and thus irrelevant to the assessee's transactions. Legal basis: absence of incriminating material and reliance on Supreme Court precedent. Outcome: addition treating loans as bogus under section 68 is unsupported and is deleted; appeal allowed. - ITAT
Whether seized documents constituted "incriminating material" to sustain an addition under section 68: Tribunal found the assessee's books and financials consistently showed investment/trading in shares, no evidence of physical movement of goods, and no AO finding that seized Tally data were parallel books; search material related to other group entities and thus irrelevant to the assessee's transactions. Legal basis: absence of incriminating material and reliance on Supreme Court precedent. Outcome: addition treating loans as bogus under section 68 is unsupported and is deleted; appeal allowed. - ITAT
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