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 - unexplained cash deposit during the demonization period - The tribunal noted that the AO had conducted an adequate inquiry into the assessee's cash deposits, purchases, and sales, and had accepted the return of income after verification. It was found that the PCIT's order u/s 263 was based on re-evaluation of the same material already considered by the AO without any new evidence or inquiry that justified a revision u/s 263. - The ITAT concluded that the AO's order was not erroneous nor prejudicial to the interest of the revenue.
Revision u/s 263 - unexplained cash deposit during the demonization period - The tribunal noted that the AO had conducted an adequate inquiry into the assessee's cash deposits, purchases, and sales, and had accepted the return of income after verification. It was found that the PCIT's order u/s 263 was based on re-evaluation of the same material already considered by the AO without any new evidence or inquiry that justified a revision u/s 263. - The ITAT concluded that the AO's order was not erroneous nor prejudicial to the interest of the revenue.
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