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...
Penalty under section 270A could not be adjudicated because the quantum addition forming its basis had already been restored for fresh consideration under the applicable double taxation avoidance agreement. With the underlying addition no longer final, the penalty appeal was premature. The matter was therefore sent back for fresh decision by the Assessing Officer, who was directed to consider whether penalty proceedings should be initiated only after the outcome of the quantum proceedings.
Penalty under section 270A could not be adjudicated because the quantum addition forming its basis had already been restored for fresh consideration under the applicable double taxation avoidance agreement. With the underlying addition no longer final, the penalty appeal was premature. The matter was therefore sent back for fresh decision by the Assessing Officer, who was directed to consider whether penalty proceedings should be initiated only after the outcome of the quantum proceedings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4830 
Join Channel 
