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...
Recorded bank credits supported by books of account, confirmations, returns, ledgers and bank statements could not be treated as unexplained money under section 69A, because the assessee was not shown to be the owner of unrecorded money and the addition lacked corroborative evidence that the funds were undisclosed income. The deletion of the addition, including the cash deposit component, was upheld. Reassessment also failed because the recorded reasons rested on incorrect facts: the assessee was said to have three bank accounts and higher non-cash credits, but verification showed only one bank account and the alleged information was wrong. The section 148 notice and reassessment proceedings were therefore held unsustainable.
Recorded bank credits supported by books of account, confirmations, returns, ledgers and bank statements could not be treated as unexplained money under section 69A, because the assessee was not shown to be the owner of unrecorded money and the addition lacked corroborative evidence that the funds were undisclosed income. The deletion of the addition, including the cash deposit component, was upheld. Reassessment also failed because the recorded reasons rested on incorrect facts: the assessee was said to have three bank accounts and higher non-cash credits, but verification showed only one bank account and the alleged information was wrong. The section 148 notice and reassessment proceedings were therefore held unsustainable.
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