Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
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Validity of 158BD proceedings - prior to 04.09.1997, i.e., the date on which jurisdiction u/s 158BD was assumed, the books of account were not handed over to the assessee. - Since the AO in the instant case has taken recourse to section 158BD before receipt of the seized material, therefore, the 158BD jurisdictional conditions cannot be said to have been met. Therefore, the entire proceedings u/s 158BD/143(3) are vitiated and, therefore, such 158BD proceedings which are not in accordance with the law are quashed - AT
Validity of 158BD proceedings - prior to 04.09.1997, i.e., the date on which jurisdiction u/s 158BD was assumed, the books of account were not handed over to the assessee. - Since the AO in the instant case has taken recourse to section 158BD before receipt of the seized material, therefore, the 158BD jurisdictional conditions cannot be said to have been met. Therefore, the entire proceedings u/s 158BD/143(3) are vitiated and, therefore, such 158BD proceedings which are not in accordance with the law are quashed - AT
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