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...
Deduction for donations to unrecognized political parties was denied for lack of evidence of a direct nexus to a backdoor benefit; the revenue failed to prove the donations were bogus, so the deduction was allowed. Separate challenge to penalty was addressed on the basis that the quantum additions were deleted; as the additions underpinning the penalty no longer survive, the penalty cannot be sustained and is therefore set aside. The tribunal applied the evidentiary requirement that revenue must establish direct benefit or commission return and relied on precedent that deletion of quantum removes the basis for penalty.
Deduction for donations to unrecognized political parties was denied for lack of evidence of a direct nexus to a backdoor benefit; the revenue failed to prove the donations were bogus, so the deduction was allowed. Separate challenge to penalty was addressed on the basis that the quantum additions were deleted; as the additions underpinning the penalty no longer survive, the penalty cannot be sustained and is therefore set aside. The tribunal applied the evidentiary requirement that revenue must establish direct benefit or commission return and relied on precedent that deletion of quantum removes the basis for penalty.
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