Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
Electronic evidence lacking valid certification, proven device control, seizure records, chain of custody, hash value or corroboration cannot support income-tax additions. Digital ledger entries representing dummy, contra, adjustment or opening balances, without proof of actual receipt, do not justify unexplained-credit additions; unauthenticated WhatsApp chats alone likewise cannot establish unexplained money. Routine leased-premises repairs and annual software upgrades are revenue expenditure, whereas multi-period licence costs require apportionment under accrual and matching principles. Post-search assessments for covered preceding years must follow the prescribed reassessment procedure; use of regular scrutiny assessment is jurisdictionally defective.
Electronic evidence lacking valid certification, proven device control, seizure records, chain of custody, hash value or corroboration cannot support income-tax additions. Digital ledger entries representing dummy, contra, adjustment or opening balances, without proof of actual receipt, do not justify unexplained-credit additions; unauthenticated WhatsApp chats alone likewise cannot establish unexplained money. Routine leased-premises repairs and annual software upgrades are revenue expenditure, whereas multi-period licence costs require apportionment under accrual and matching principles. Post-search assessments for covered preceding years must follow the prescribed reassessment procedure; use of regular scrutiny assessment is jurisdictionally defective.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
