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 - period of limitation for passing order - Only in a case where the issues before the Commissioner at the time of exercising powers u/s 263 relate to the subject matter of re-assessment, the limitation would start from the date of Re-assessment Order. However, if the subject matter of the re-assessment is distinct and different, in that case the relevant date for the purpose of determination of period of limitation for exercising powers u/s 263 would be the date of the original Assessment Order. - SC
Revision u/s 263 - period of limitation for passing order - Only in a case where the issues before the Commissioner at the time of exercising powers u/s 263 relate to the subject matter of re-assessment, the limitation would start from the date of Re-assessment Order. However, if the subject matter of the re-assessment is distinct and different, in that case the relevant date for the purpose of determination of period of limitation for exercising powers u/s 263 would be the date of the original Assessment Order. - SC
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