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...
Validity of the assessment order passed u/s 147 r.w.s. 143(3) - post search assessment - in the case on hand the pending reassessment proceedings u/s 147 got abated by virtue of 2nd proviso to section 153A(1) - once the reassessment proceedings initiated vide notice u/s 148 stood abated by virtue of search and seizure action u/s 132(1) carried out then the reassessment order passed by the AO u/s 147 r.w.s. 143(3) is illegal and void-ab-initio and liable to be quashed. - AT
Validity of the assessment order passed u/s 147 r.w.s. 143(3) - post search assessment - in the case on hand the pending reassessment proceedings u/s 147 got abated by virtue of 2nd proviso to section 153A(1) - once the reassessment proceedings initiated vide notice u/s 148 stood abated by virtue of search and seizure action u/s 132(1) carried out then the reassessment order passed by the AO u/s 147 r.w.s. 143(3) is illegal and void-ab-initio and liable to be quashed. - AT
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