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 - AO was clinched with tangible information in the shape of information from Sales Tax Authorities which prima-facie suggested possible escapement of income - sanction u/s 151(2) is not required as proceedings were triggered within 4 years and first proviso to Section 147 was not applicable since the original return was processed u/s 143(1) - reopening upheld
Re-assessment u/s 147 - AO was clinched with tangible information in the shape of information from Sales Tax Authorities which prima-facie suggested possible escapement of income - sanction u/s 151(2) is not required as proceedings were triggered within 4 years and first proviso to Section 147 was not applicable since the original return was processed u/s 143(1) - reopening upheld
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