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...
Reopening of assessment - Reason to belief - Addition u/s 69 was made in assessment u/s 143(3) r.w.s 153A - if such income has already been assessed then the AO could not have formed the belief that income chargeable to tax has escaped assessment, The assumption of jurisdiction u/s 147 of the Act on the part of the AO therefore, lacks validity and hence, cannot be sustained.
Reopening of assessment - Reason to belief - Addition u/s 69 was made in assessment u/s 143(3) r.w.s 153A - if such income has already been assessed then the AO could not have formed the belief that income chargeable to tax has escaped assessment, The assumption of jurisdiction u/s 147 of the Act on the part of the AO therefore, lacks validity and hence, cannot be sustained.
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