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...
Rectification u/s 154 - Modification of order more than 10-year-old order - The interest u/s 234B and u/s 234C has not been charged while issuing the intimation and the demand raised as per the record was Nil. The date of order u/s 154 was 16.01.2017 pertaining to the Assessment Order passed u/s 153A and date of rectification order u/s 154 r.w.s. 254/143(3) was dated 09.12.2020 which tried to modify the order of 2009 - the order of the rectification, rectifying the order of the earlier decade is barred by limitation and cannot be held to be legally valid. - AT
Rectification u/s 154 - Modification of order more than 10-year-old order - The interest u/s 234B and u/s 234C has not been charged while issuing the intimation and the demand raised as per the record was Nil. The date of order u/s 154 was 16.01.2017 pertaining to the Assessment Order passed u/s 153A and date of rectification order u/s 154 r.w.s. 254/143(3) was dated 09.12.2020 which tried to modify the order of 2009 - the order of the rectification, rectifying the order of the earlier decade is barred by limitation and cannot be held to be legally valid. - AT
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