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 assessment order - copy of the SIB report not provided to the assessee - The court held that the petitioner's version was not considered by the authorities due to its non-appearance before the appellate authority and that the petitioner was not provided with a copy of the SIB report, despite the entire assessment being based on it. This lack of access to crucial information severely prejudiced the petitioner's ability to defend itself, constituting a violation of natural justice. - The adjudicating authority is directed to provide the petitioner with a copy of the SIB report and any other material forming the basis of the demands and adjudicate the matter providing a full opportunity of hearing to the petitioner.
Validity of assessment order - copy of the SIB report not provided to the assessee - The court held that the petitioner's version was not considered by the authorities due to its non-appearance before the appellate authority and that the petitioner was not provided with a copy of the SIB report, despite the entire assessment being based on it. This lack of access to crucial information severely prejudiced the petitioner's ability to defend itself, constituting a violation of natural justice. - The adjudicating authority is directed to provide the petitioner with a copy of the SIB report and any other material forming the basis of the demands and adjudicate the matter providing a full opportunity of hearing to the petitioner.
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