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 approval u/s 153D was mechanically granted without proper application of mind, violating principles of natural justice. The sanctioning authority failed to ensure complete documentation and opportunity of hearing for the assessee regarding a valuer's report. Consequently, the approval was deemed invalid, rendering the consequential assessment void ab initio. The tribunal quashed the assessment proceedings due to non-satisfaction of statutory mandates, ultimately allowing the assessee's appeal and invalidating the entire assessment process.
ITAT held that the approval u/s 153D was mechanically granted without proper application of mind, violating principles of natural justice. The sanctioning authority failed to ensure complete documentation and opportunity of hearing for the assessee regarding a valuer's report. Consequently, the approval was deemed invalid, rendering the consequential assessment void ab initio. The tribunal quashed the assessment proceedings due to non-satisfaction of statutory mandates, ultimately allowing the assessee's appeal and invalidating the entire assessment process.
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