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 - notice under section 148 has been issued by a non jurisdictional AO - It is settled principle of law that when the notice under section 148 of the Act has been issued by a non jurisdictional AO, the ITO Bareli in this case, reassessment by the jurisdictional AO is bad in law and is liable to be quashed, more particularly when assessment of the assessee has admittedly not been transferred to Bareli under section 127 of the Act. - AT
Reopening of assessment u/s 147 - notice under section 148 has been issued by a non jurisdictional AO - It is settled principle of law that when the notice under section 148 of the Act has been issued by a non jurisdictional AO, the ITO Bareli in this case, reassessment by the jurisdictional AO is bad in law and is liable to be quashed, more particularly when assessment of the assessee has admittedly not been transferred to Bareli under section 127 of the Act. - AT
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