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...
Where addition was made solely on an estimated net profit basis, such estimate falls outside "under-reporting of income" under section 270A(6)(b) provided the accounts are correct and complete to the satisfaction of the assessing officer; accordingly the estimation does not sustain penalty as under-reporting. Separately, penalty proceedings were vitiated by failure to specify the statutory limb of section 270A (whether clauses (2)(a)-(g) or (9)(a)-(f)), rendering initiation of penalty legally untenable; consequence: penalty deleted and appeal allowed. - ITAT
Where addition was made solely on an estimated net profit basis, such estimate falls outside "under-reporting of income" under section 270A(6)(b) provided the accounts are correct and complete to the satisfaction of the assessing officer; accordingly the estimation does not sustain penalty as under-reporting. Separately, penalty proceedings were vitiated by failure to specify the statutory limb of section 270A (whether clauses (2)(a)-(g) or (9)(a)-(f)), rendering initiation of penalty legally untenable; consequence: penalty deleted and appeal allowed. - ITAT
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