Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
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HC held that Section 65B of the Indian Evidence Act, 1872 and corresponding provisions in Bharatiya Sakshya Adhiniyam, 2023 are inapplicable to income tax assessment proceedings. The court determined that technical evidentiary rules do not govern such administrative proceedings. Electronic records seized from the assessee's systems can be admitted without mandatory expert certification. While the assessee retains the right to challenge the genuineness of electronic materials, procedural technicalities cannot shield them from scrutiny. The court emphasized that departmental manuals lack statutory force and cannot override established legal principles regarding evidence admission in assessment proceedings.
HC held that Section 65B of the Indian Evidence Act, 1872 and corresponding provisions in Bharatiya Sakshya Adhiniyam, 2023 are inapplicable to income tax assessment proceedings. The court determined that technical evidentiary rules do not govern such administrative proceedings. Electronic records seized from the assessee's systems can be admitted without mandatory expert certification. While the assessee retains the right to challenge the genuineness of electronic materials, procedural technicalities cannot shield them from scrutiny. The court emphasized that departmental manuals lack statutory force and cannot override established legal principles regarding evidence admission in assessment proceedings.
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