International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
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WhatsApp chats alone cannot sustain an addition treating part of an agreed consideration as unexplained investment; corroboration in seized material and statements is required and lacking here, so the addition under section 69 read with section 115BBE was deleted. The statutory presumption in favour of documents found during search must be applied by reading seized documents and recorded statements collectively; a holistic appraisal of draft agreements, estimates, board resolution and statements supported the taxpayer's position that the alleged cash related to a proposed refurbishment not carried out or paid. The Revenue failed to discharge the burden to establish unexplained investment.
WhatsApp chats alone cannot sustain an addition treating part of an agreed consideration as unexplained investment; corroboration in seized material and statements is required and lacking here, so the addition under section 69 read with section 115BBE was deleted. The statutory presumption in favour of documents found during search must be applied by reading seized documents and recorded statements collectively; a holistic appraisal of draft agreements, estimates, board resolution and statements supported the taxpayer's position that the alleged cash related to a proposed refurbishment not carried out or paid. The Revenue failed to discharge the burden to establish unexplained investment.
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