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...
Settlement Commission lacks power to rectify order u/s 245F(1) by levying interest u/ss 234A, 234B, and 234C prior to 01.06.2011. Rectification order on 21.03.2003 was invalid as Settlement Commission did not have rectification power then. Supreme Court in Brij Lal case held interest u/s 234B is leviable only till date of order u/s 245D(1), not till Settlement Order u/s 245D(4). Settlement Commission cannot reopen concluded proceedings invoking Section 154 to levy interest u/s 234B due to Section 245I restriction.
Settlement Commission lacks power to rectify order u/s 245F(1) by levying interest u/ss 234A, 234B, and 234C prior to 01.06.2011. Rectification order on 21.03.2003 was invalid as Settlement Commission did not have rectification power then. Supreme Court in Brij Lal case held interest u/s 234B is leviable only till date of order u/s 245D(1), not till Settlement Order u/s 245D(4). Settlement Commission cannot reopen concluded proceedings invoking Section 154 to levy interest u/s 234B due to Section 245I restriction.
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