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 - Bogus long term capital gain through share transaction of a penny stock company - The tribunal observed that the Pr. CIT based the revision on the same grounds as the initial reopening, without thoroughly investigating or highlighting specific errors or deficiencies in the assessee’s submissions or in the NFAC's assessment. - The tribunal decisively ruled in favor of the assessee, finding that the Pr. CIT’s use of Section 263 was unjustified given the thorough inquiries already conducted during the reassessment.
Validity of Revision u/s 263 - Bogus long term capital gain through share transaction of a penny stock company - The tribunal observed that the Pr. CIT based the revision on the same grounds as the initial reopening, without thoroughly investigating or highlighting specific errors or deficiencies in the assessee’s submissions or in the NFAC's assessment. - The tribunal decisively ruled in favor of the assessee, finding that the Pr. CIT’s use of Section 263 was unjustified given the thorough inquiries already conducted during the reassessment.
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