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Summary: The ITAT Delhi in DCIT vs. Balar Marketing Pvt. Ltd. held that additions in search assessments cannot be sustained solely on unauthenticated electronic evidence such as WhatsApp chats, SMS messages, and screenshots of alleged parallel accounts without strict adherence to evidentiary principles. In this case, the Revenue relied entirely on digital data extracted from seized devices and statements recorded during search, without any corroborative material like stock discrepancies or third-party confirmations. The Tribunal emphasized that even though strict rules of the Indian Evidence A...
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Ajay Kumar Agrawal FCA, a science graduate and fellow chartered accountant in practice for over 26 years. Ajay has been in continuous practice mainly in corporate consultancy, litigation in the field of Direct and Indirect laws, Regulatory Law, and commercial law beside the Auditing of corporate and View Full Profile

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ITAT Reduces Section 271(1)(b) Penalty by treating Multiple Notice Defaults as One Section 54 Exemption Allowed as Investment Was Made Within 2 Years Despite No CGDS Deposit ITAT Deletes Section 68 Addition Since Opening Loan Balances Cannot Be Taxed Again ITAT Delhi Deletes Capital Addition as No Liability Cessation Was Proved ITAT Quashes Assessment Due to Non-Supply of Search Material View More Published Posts

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