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...
Cross-examination of persons whose statements are relied upon in GST penalty proceedings is necessary to satisfy principles of natural justice where the affected party specifically requests it. Denial of that opportunity before imposing penalty constitutes a serious procedural defect. The penalty order and consequential notices were set aside, with fresh consideration required after supplying relevant documents, granting a personal hearing, permitting cross-examination of relied-upon persons, and allowing a fresh reply. The merits of the underlying allegations remained open for independent reconsideration.
Cross-examination of persons whose statements are relied upon in GST penalty proceedings is necessary to satisfy principles of natural justice where the affected party specifically requests it. Denial of that opportunity before imposing penalty constitutes a serious procedural defect. The penalty order and consequential notices were set aside, with fresh consideration required after supplying relevant documents, granting a personal hearing, permitting cross-examination of relied-upon persons, and allowing a fresh reply. The merits of the underlying allegations remained open for independent reconsideration.
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