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...
Addition of excess jewellery found in search - The Court interpreted CBDT Instruction 1916 and emphasized that it pertains to the seizure stage and does not dictate assessment procedures. It allows discretion to exclude larger quantities of jewellery from seizure based on factors like family status and community customs. Since the circular is applicable only during the seizure stage, the Court ruled that the respondent's failure to follow it during assessment does not warrant interference. The Court reminded the petitioner of the availability of an alternate remedy before the Appellate Commissioner u/s 246A of the Income Tax Act.
Addition of excess jewellery found in search - The Court interpreted CBDT Instruction 1916 and emphasized that it pertains to the seizure stage and does not dictate assessment procedures. It allows discretion to exclude larger quantities of jewellery from seizure based on factors like family status and community customs. Since the circular is applicable only during the seizure stage, the Court ruled that the respondent's failure to follow it during assessment does not warrant interference. The Court reminded the petitioner of the availability of an alternate remedy before the Appellate Commissioner u/s 246A of the Income Tax Act.
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