Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
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Reopening of assessment u/s 147 - assessment is in pursuance of an order on appeal, etc. u/s 150 - Already order of the Tribunal has been given effect to by the assessing officer for the assessment year 1995-96 by the consequential order dated 21.12.2005. That being the position, it was not open to the assessing officer to have once again issued a notice under Section 148 r.w.s. 150 of the Act to reopen the assessment for the assessment year 1995-96, that too, on a different issue unconnected with the order of the Tribunal. - HC
Reopening of assessment u/s 147 - assessment is in pursuance of an order on appeal, etc. u/s 150 - Already order of the Tribunal has been given effect to by the assessing officer for the assessment year 1995-96 by the consequential order dated 21.12.2005. That being the position, it was not open to the assessing officer to have once again issued a notice under Section 148 r.w.s. 150 of the Act to reopen the assessment for the assessment year 1995-96, that too, on a different issue unconnected with the order of the Tribunal. - HC
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