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 suggestion of DDIT(Inv.) does not confer power to assume jurisdiction upon the AO to initiate reassessment proceedings - notice u/s 148 was issued without any application of mind and examination of the so called material and information received from the investigation wing to establish any nexus, even prima facie, with such information, by way of borrowed satisfaction - not sustainable
Reassessment u/s 147 - the suggestion of DDIT(Inv.) does not confer power to assume jurisdiction upon the AO to initiate reassessment proceedings - notice u/s 148 was issued without any application of mind and examination of the so called material and information received from the investigation wing to establish any nexus, even prima facie, with such information, by way of borrowed satisfaction - not sustainable
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