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...
Final assessment order passed u/s 143(3) read with Section 144C(13) subsequent to Dispute Resolution Panel (DRP)/Transfer Pricing Officer (TPO) directions deemed invalid due to non-compliance with statutory provisions. Assessing Officer failed to follow DRP directions and pass rectification order as mandated. TPO issued Order Giving Effect (OGE) to TP adjustments post-DRP directions, forming part of assessment records. However, Assessing Officer's non-compliance constituted gross violation of Section 144C, rendering final assessment order contrary to the Act. Despite Revenue arguing it as a mistake, no efforts were made to rectify within reasonable time, violating law. Final assessment order quashed, assessee favored.
Final assessment order passed u/s 143(3) read with Section 144C(13) subsequent to Dispute Resolution Panel (DRP)/Transfer Pricing Officer (TPO) directions deemed invalid due to non-compliance with statutory provisions. Assessing Officer failed to follow DRP directions and pass rectification order as mandated. TPO issued Order Giving Effect (OGE) to TP adjustments post-DRP directions, forming part of assessment records. However, Assessing Officer's non-compliance constituted gross violation of Section 144C, rendering final assessment order contrary to the Act. Despite Revenue arguing it as a mistake, no efforts were made to rectify within reasonable time, violating law. Final assessment order quashed, assessee favored.
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