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...
ITAT held that the assessment order under sec. 153C was invalid due to lack of proper satisfaction regarding incriminating material. The AO failed to establish a direct correlation between search materials and the assessee's income for AY 2019-2020. Consequently, the PCIT's revisionary order under sec. 263 was deemed illegal and void ab initio. The tribunal emphasized that an illegal assessment order cannot be legitimized through revisionary powers. The order was ultimately decided in favor of the assessee, quashing both the assessment order and the revisionary proceedings.
ITAT held that the assessment order under sec. 153C was invalid due to lack of proper satisfaction regarding incriminating material. The AO failed to establish a direct correlation between search materials and the assessee's income for AY 2019-2020. Consequently, the PCIT's revisionary order under sec. 263 was deemed illegal and void ab initio. The tribunal emphasized that an illegal assessment order cannot be legitimized through revisionary powers. The order was ultimately decided in favor of the assessee, quashing both the assessment order and the revisionary proceedings.
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