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...
The HC held that the jurisdictional assessing officer (JAO) who issued the original notices under the old regime can continue reassessment proceedings and pass assessment orders under the new faceless regime (FAO). Treating the old notices as issued u/s 148A, the JAO is entitled to examine replies, take decisions, and pass reassessment orders following the new procedures. The HC disagreed with contrary views of Telangana HC and distinguished other cases. Petitions were dismissed, allowing JAO to decide on merits with condonation of delay due to pending writ petitions.
The HC held that the jurisdictional assessing officer (JAO) who issued the original notices under the old regime can continue reassessment proceedings and pass assessment orders under the new faceless regime (FAO). Treating the old notices as issued u/s 148A, the JAO is entitled to examine replies, take decisions, and pass reassessment orders following the new procedures. The HC disagreed with contrary views of Telangana HC and distinguished other cases. Petitions were dismissed, allowing JAO to decide on merits with condonation of delay due to pending writ petitions.
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