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...
Reassessment u/s 147 - The full and true disclosure of the assessee is not in doubt - The ‘recording of reasons’ is mechanical and robotic and the mandate u/s 147 has not been complied with - It was incumbent upon the AO to have had independent ‘reasons to believe’ that there is escapement of tax, even if the initial nudge did emanate from the audit department - reassessment quashed
Reassessment u/s 147 - The full and true disclosure of the assessee is not in doubt - The ‘recording of reasons’ is mechanical and robotic and the mandate u/s 147 has not been complied with - It was incumbent upon the AO to have had independent ‘reasons to believe’ that there is escapement of tax, even if the initial nudge did emanate from the audit department - reassessment quashed
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