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 - The assessee has filed her return of income. AO has not made any analysis on what the assessee has claimed, how prima-facie the claim of the assessee could be bogus on the basis of the information supplied by the Investigation Wing and therefore an income appears to have been escaped! Section 147 nowhere authorizes the Assessing Officer to reopen an assessment for verification of the claim made by the assessee. - AT
Reopening of assessment u/s 147 - The assessee has filed her return of income. AO has not made any analysis on what the assessee has claimed, how prima-facie the claim of the assessee could be bogus on the basis of the information supplied by the Investigation Wing and therefore an income appears to have been escaped! Section 147 nowhere authorizes the Assessing Officer to reopen an assessment for verification of the claim made by the assessee. - AT
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