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...
Related-party payment under section 40A(2)(a) cannot be disallowed unless excessiveness is tested against a truly comparable service; email marketing charges were deleted because the Assessing Officer compared dissimilar services and the record did not support the conclusion of excess payment. Depreciation and car-loan interest were allowed where the vehicles were kept ready for use, since actual use is not the sole test for business assets maintained in a state of readiness. Recruitment, placement and staff welfare es were disallowed because the assessee had admitted during assessment that no employees existed during the year and the amount was offered for disallowance.
Related-party payment under section 40A(2)(a) cannot be disallowed unless excessiveness is tested against a truly comparable service; email marketing charges were deleted because the Assessing Officer compared dissimilar services and the record did not support the conclusion of excess payment. Depreciation and car-loan interest were allowed where the vehicles were kept ready for use, since actual use is not the sole test for business assets maintained in a state of readiness. Recruitment, placement and staff welfare es were disallowed because the assessee had admitted during assessment that no employees existed during the year and the amount was offered for disallowance.
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