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...
HC quashed and set aside order dated 24 January 2024 rejecting condonation application for delayed income tax return filing. Court found Additional CIT (OSD) (OT & WT) lacked authority to issue orders under s.119(2)(b) of Income Tax Act, as this power vests with CBDT. While CBDT may allocate work among members, no evidence demonstrated valid delegation to Additional CIT. Matter remanded to CBDT or authorized member for fresh consideration with directions to hear petitioner and issue reasoned order within 3 months. Ruling clarified procedural requirements for exercising powers under s.119(2)(b), emphasizing proper authority and delegation channels.
HC quashed and set aside order dated 24 January 2024 rejecting condonation application for delayed income tax return filing. Court found Additional CIT (OSD) (OT & WT) lacked authority to issue orders under s.119(2)(b) of Income Tax Act, as this power vests with CBDT. While CBDT may allocate work among members, no evidence demonstrated valid delegation to Additional CIT. Matter remanded to CBDT or authorized member for fresh consideration with directions to hear petitioner and issue reasoned order within 3 months. Ruling clarified procedural requirements for exercising powers under s.119(2)(b), emphasizing proper authority and delegation channels.
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