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...
Reopening of assessment u/s 147 - appropriate authority for issuance of the notice - The High Court found merit in the petitioner's argument regarding the lack of jurisdictional authority for issuing the notices. It relied on the decision in Twylight Infrastructure Pvt. Ltd. v. ITO & Ors. and ruled in favor of the petitioner. While the petitioner raised concerns about the reassessment proceedings being based on a change of opinion, the High Court's decision primarily focused on the jurisdictional issue.
Reopening of assessment u/s 147 - appropriate authority for issuance of the notice - The High Court found merit in the petitioner's argument regarding the lack of jurisdictional authority for issuing the notices. It relied on the decision in Twylight Infrastructure Pvt. Ltd. v. ITO & Ors. and ruled in favor of the petitioner. While the petitioner raised concerns about the reassessment proceedings being based on a change of opinion, the High Court's decision primarily focused on the jurisdictional issue.
Note: It is a system-generated summary and is for quick reference only.