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...
Reopening of assessment u/s 147 - validity of reason to believe - ‘borrowed satisfaction’ of the DDIT (Inv.) - The repetition of certain portions of the investigation report of DDIT without any reasons independently recorded by the AO on the basis of ‘borrowed satisfaction’ of the DDIT (Inv.) cannot be the basis for reopening of assessment u/s. 147 of the Act.
Reopening of assessment u/s 147 - validity of reason to believe - ‘borrowed satisfaction’ of the DDIT (Inv.) - The repetition of certain portions of the investigation report of DDIT without any reasons independently recorded by the AO on the basis of ‘borrowed satisfaction’ of the DDIT (Inv.) cannot be the basis for reopening of assessment u/s. 147 of the Act.
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