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...
Approval granted u/s 153D of the Act should reflect due application of mind by the designated authority and not be a mechanical exercise. Perfunctory approval without scrutinizing seized documents and materials forming the foundation of assessment lacks legal sanctity. The obligation of granting approval acts as an inbuilt protection against arbitrary or unjust exercise of discretion by the assessing officer. Approval granted in a mechanical manner defeats the purpose of obtaining approval u/s 153D. The impugned assessment order, consequent to such inexplicable approval, lacks legitimacy and is non-est and a nullity, liable to be quashed.
Approval granted u/s 153D of the Act should reflect due application of mind by the designated authority and not be a mechanical exercise. Perfunctory approval without scrutinizing seized documents and materials forming the foundation of assessment lacks legal sanctity. The obligation of granting approval acts as an inbuilt protection against arbitrary or unjust exercise of discretion by the assessing officer. Approval granted in a mechanical manner defeats the purpose of obtaining approval u/s 153D. The impugned assessment order, consequent to such inexplicable approval, lacks legitimacy and is non-est and a nullity, liable to be quashed.
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