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...
Violation of principles of natural justice - It was contended that impugned order does not take into consideration the reply submitted by the Petitioner and is a cryptic order - The High Court found that the impugned order failed to properly consider the petitioner's detailed reply. Instead, it merely stated that the reply was unsatisfactory without providing specific reasons or engaging with the content of the response. This lack of substantive consideration indicated that the Proper Officer did not apply their mind to the petitioner's submission. - Matter restored back for reconsideration.
Violation of principles of natural justice - It was contended that impugned order does not take into consideration the reply submitted by the Petitioner and is a cryptic order - The High Court found that the impugned order failed to properly consider the petitioner's detailed reply. Instead, it merely stated that the reply was unsatisfactory without providing specific reasons or engaging with the content of the response. This lack of substantive consideration indicated that the Proper Officer did not apply their mind to the petitioner's submission. - Matter restored back for reconsideration.
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