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 - When the issue is a jurisdictional one, the provisions of Section 292BB of the Act cannot cure jurisdictional error. On perusal of the appellate order, it is also clear that the CIT(A) has discussed the jurisdictional issue raised by the assessee, however, he has rejected the contention of the assessee, which in our opinion, amounts to overruling the CBDT Instruction issued in this regard. - AT
Reopening of assessment u/s 147 - When the issue is a jurisdictional one, the provisions of Section 292BB of the Act cannot cure jurisdictional error. On perusal of the appellate order, it is also clear that the CIT(A) has discussed the jurisdictional issue raised by the assessee, however, he has rejected the contention of the assessee, which in our opinion, amounts to overruling the CBDT Instruction issued in this regard. - AT
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