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 - assessment u/s 147 - The language employed by the statute (i.e., w.e.f. 01/6/2015) in this regard, i.e., 'an order passed without making further inquiries or verification which should have been made.' is apposite. It is the inquiry/verification by the AO that is relevant for the purpose, and not the explanation/s, if any, furnished before the appellate authority, much less that de hors the record.- AT
Revision u/s 263 - assessment u/s 147 - The language employed by the statute (i.e., w.e.f. 01/6/2015) in this regard, i.e., 'an order passed without making further inquiries or verification which should have been made.' is apposite. It is the inquiry/verification by the AO that is relevant for the purpose, and not the explanation/s, if any, furnished before the appellate authority, much less that de hors the record.- AT
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