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 - In the instant case, since the fact of furnishing of the reasons recorded by the AO has not been established and keeping in view, the fact that the revenue could not provide any evidence to prove that the reasons recorded indeed have been supplied to the assessee, we hereby hold that the reassessment proceedings are vitiated. - AT
Reopening of assessment u/s 147 - In the instant case, since the fact of furnishing of the reasons recorded by the AO has not been established and keeping in view, the fact that the revenue could not provide any evidence to prove that the reasons recorded indeed have been supplied to the assessee, we hereby hold that the reassessment proceedings are vitiated. - AT
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