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...
Revision u/s 263 by CIT - If there are no materials on record on the basis of which it can be said that the Commissioner acting in a reasonable manner could have come to such a conclusion, the very initiation of proceedings by him will be illegal and without jurisdiction. TCommissioner cannot initiate proceedings with a view to starting fishing and roving enquiries in matters or orders which are already concluded. - AT
Revision u/s 263 by CIT - If there are no materials on record on the basis of which it can be said that the Commissioner acting in a reasonable manner could have come to such a conclusion, the very initiation of proceedings by him will be illegal and without jurisdiction. TCommissioner cannot initiate proceedings with a view to starting fishing and roving enquiries in matters or orders which are already concluded. - AT
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