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 - existence of Settlement Commission order in the relevant AY - concluded assessment by Settlement Commission u/s 245D(4) can only be reopened in case of fraud or misrepresentation of facts, as per section 245D(6) - the assumption of jurisdiction u/s 147 is invalid and without authority of law irrespective of sufficient material for the AO to form the belief for escaped assessment
Reassessment u/s 147 - existence of Settlement Commission order in the relevant AY - concluded assessment by Settlement Commission u/s 245D(4) can only be reopened in case of fraud or misrepresentation of facts, as per section 245D(6) - the assumption of jurisdiction u/s 147 is invalid and without authority of law irrespective of sufficient material for the AO to form the belief for escaped assessment
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