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...
Re-assessment u/s 147 - no failure on the part of the assessee to disclose all the relevant facts truly and fully for assessment - AO cannot have a mere re-appreciation of the same facts or a review of existing material on a mere change of opinion and take a different view of the matter - limitation of 4 years is a protection of whimsical and arbitrary re-assessment proceedings
Re-assessment u/s 147 - no failure on the part of the assessee to disclose all the relevant facts truly and fully for assessment - AO cannot have a mere re-appreciation of the same facts or a review of existing material on a mere change of opinion and take a different view of the matter - limitation of 4 years is a protection of whimsical and arbitrary re-assessment proceedings
Note: It is a system-generated summary and is for quick reference only.