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...
Addition for unexplained investment could not stand where it rested only on third-party statements and seized material from another group entity, without any independent corroborative evidence linking the assessee to payment of on-money. The Tribunal also noted that denial of cross-examination when such third-party statements are relied upon vitiates the addition in natural justice terms. Following co-ordinate Bench decisions on identical facts involving the same group, it deleted the addition under section 69 and allowed the assessee's appeals for the relevant years.
Addition for unexplained investment could not stand where it rested only on third-party statements and seized material from another group entity, without any independent corroborative evidence linking the assessee to payment of on-money. The Tribunal also noted that denial of cross-examination when such third-party statements are relied upon vitiates the addition in natural justice terms. Following co-ordinate Bench decisions on identical facts involving the same group, it deleted the addition under section 69 and allowed the assessee's appeals for the relevant years.
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