Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
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Revision u/s 263 - another possible view of the matter - The appellant challenged the jurisdiction of the PCIT, arguing that the original assessment order by the AO was not erroneous and did not prejudice the revenue. - The ITAT found that the AO had duly examined the submissions and evidence before concluding the assessment. The PCIT's order was deemed unsustainable as it was based on grounds not part of the initial reasons for scrutiny and lacked sufficient basis. Consequently, the Tribunal set aside the PCIT's order and upheld the decision of the AO.
Revision u/s 263 - another possible view of the matter - The appellant challenged the jurisdiction of the PCIT, arguing that the original assessment order by the AO was not erroneous and did not prejudice the revenue. - The ITAT found that the AO had duly examined the submissions and evidence before concluding the assessment. The PCIT's order was deemed unsustainable as it was based on grounds not part of the initial reasons for scrutiny and lacked sufficient basis. Consequently, the Tribunal set aside the PCIT's order and upheld the decision of the AO.
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