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 reopening of assessment - Re-opening notice u/s 148A(d) - personal hearing refused - the High court concluded that Section 148A(b) does not mandate a personal hearing. The provision requires serving a show cause notice, but the specific words "personal hearing" are not included in the section. - It was noted that while the Income Tax Department may grant a personal hearing at its discretion, refusal to grant such a hearing would not mean that the assessee has been deprived of an opportunity of hearing, as long as there is no specific provision in the statute mandating such a hearing.
Validity of reopening of assessment - Re-opening notice u/s 148A(d) - personal hearing refused - the High court concluded that Section 148A(b) does not mandate a personal hearing. The provision requires serving a show cause notice, but the specific words "personal hearing" are not included in the section. - It was noted that while the Income Tax Department may grant a personal hearing at its discretion, refusal to grant such a hearing would not mean that the assessee has been deprived of an opportunity of hearing, as long as there is no specific provision in the statute mandating such a hearing.
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