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 reassessment proceedings challenged - capital gain on co-owned land sale - reassessment based on DVO report alleging suppression of lower valuation - reasons recorded did not mention forming reason to believe due to DVO report in co-owner's case - reliance on DVO report to justify reopening untenable as no fresh material part of recorded reasons - petitioner fully disclosed material facts during original assessment - change of opinion for reopening by impugned notice u/s 148 untenable - impugned notice unsustainable - assessee entitled to benefit enjoyed by co-owners whose valuation accepted - permitting impugned notice an exercise in futility - assessee appeal allowed.
Validity of reassessment proceedings challenged - capital gain on co-owned land sale - reassessment based on DVO report alleging suppression of lower valuation - reasons recorded did not mention forming reason to believe due to DVO report in co-owner's case - reliance on DVO report to justify reopening untenable as no fresh material part of recorded reasons - petitioner fully disclosed material facts during original assessment - change of opinion for reopening by impugned notice u/s 148 untenable - impugned notice unsustainable - assessee entitled to benefit enjoyed by co-owners whose valuation accepted - permitting impugned notice an exercise in futility - assessee appeal allowed.
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