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...
Faceless assessment regime mandated u/s 151A - Jurisdictional Assessing Officer not permitted to issue notice u/s 148, as it would breach Section 151A provisions - No concurrent jurisdiction of JAO and FAO for Section 148 notice or assessment/reassessment order issuance - Specific jurisdiction assigned to either JAO or FAO in Scheme, excluding the other - Accepting Revenue's argument would render faceless proceedings redundant - Act contrary to law by Authority must be quashed as invalid, without requiring prejudice establishment - Assessees entitled to assessment as per prescribed law and procedure - Action against assessee without due process itself causes prejudice - Decided in favor of assessee.
Faceless assessment regime mandated u/s 151A - Jurisdictional Assessing Officer not permitted to issue notice u/s 148, as it would breach Section 151A provisions - No concurrent jurisdiction of JAO and FAO for Section 148 notice or assessment/reassessment order issuance - Specific jurisdiction assigned to either JAO or FAO in Scheme, excluding the other - Accepting Revenue's argument would render faceless proceedings redundant - Act contrary to law by Authority must be quashed as invalid, without requiring prejudice establishment - Assessees entitled to assessment as per prescribed law and procedure - Action against assessee without due process itself causes prejudice - Decided in favor of assessee.
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