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 - Applicability of provisions of 56(2)(vii)(b) - Documentary evidence available in the records which the AO admits to have verified the veracity thereof amply demonstrate that the AO made the requisite enquiry. If that be so, a mere non-discussion or non-mention thereof in the assessment order could not lead to assumption that the AO did not apply his mind or that he had not made inquiry on the issue. - Revision order set aside - AT
Revision u/s 263 - Applicability of provisions of 56(2)(vii)(b) - Documentary evidence available in the records which the AO admits to have verified the veracity thereof amply demonstrate that the AO made the requisite enquiry. If that be so, a mere non-discussion or non-mention thereof in the assessment order could not lead to assumption that the AO did not apply his mind or that he had not made inquiry on the issue. - Revision order set aside - AT
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