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...
Power of CIT(A) for enhancement u/s 251(2) - Enhancing the assessed income by making disallowances of deferred revenue expenses - There is no material on record suggesting that the assessee was awarded the opportunity of being heard before the enhancement of income by the learned CIT(A). As such, the appellate authority cannot enhance the assessment without issuing show cause notice. - AT
Power of CIT(A) for enhancement u/s 251(2) - Enhancing the assessed income by making disallowances of deferred revenue expenses - There is no material on record suggesting that the assessee was awarded the opportunity of being heard before the enhancement of income by the learned CIT(A). As such, the appellate authority cannot enhance the assessment without issuing show cause notice. - AT
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