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 Revision u/s 263 - The Pr. CIT had argued that the original assessments were inadequate and missed critical checks, which purportedly rendered the assessments erroneous and adverse to revenue interests. However, the tribunal found that the assessee had provided sufficient documentation and explanations initially and during the re-assessment proceedings, which were conducted thoroughly by the assessing officer. The tribunal, therefore, set aside the revisional order issued by the Pr. CIT, reinstating the original assessment.
Validity of Revision u/s 263 - The Pr. CIT had argued that the original assessments were inadequate and missed critical checks, which purportedly rendered the assessments erroneous and adverse to revenue interests. However, the tribunal found that the assessee had provided sufficient documentation and explanations initially and during the re-assessment proceedings, which were conducted thoroughly by the assessing officer. The tribunal, therefore, set aside the revisional order issued by the Pr. CIT, reinstating the original assessment.
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