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 - subsequent revision orders - first order set aside by PCIT - ITAT quashing revisionary proceedings - adoption of accrual basis of accounting - assessee company followed mercantile system and showed trade receivables - assessee bound to adhere to Ministry of Power's direction to account for interest on cash basis - order u/s 263 invalid once first order quashed - no subsequent order permissible - res judicata principle applicable - Tribunal's order justified in absence of challenge to fundamental aspect across assessment years.
Validity of revision u/s 263 - subsequent revision orders - first order set aside by PCIT - ITAT quashing revisionary proceedings - adoption of accrual basis of accounting - assessee company followed mercantile system and showed trade receivables - assessee bound to adhere to Ministry of Power's direction to account for interest on cash basis - order u/s 263 invalid once first order quashed - no subsequent order permissible - res judicata principle applicable - Tribunal's order justified in absence of challenge to fundamental aspect across assessment years.
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