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 ITAT invalidated the assessment order due to procedural irregularities in jurisdictional transfer. The tribunal found that the assessment proceedings under Section 143(3) were initiated by one assessing officer but completed by another without a mandatory transfer order under Section 127. The tribunal disallowed capital gains deductions claimed by the appellant, observing that the transaction documents were self-manufactured, lacking genuine corroborative evidence. The ledger entries and unregistered agreements were deemed insufficient to substantiate the claimed expenses. Consequently, the assessment order was quashed for want of valid jurisdictional assumption, effectively nullifying the tax assessment.
The ITAT invalidated the assessment order due to procedural irregularities in jurisdictional transfer. The tribunal found that the assessment proceedings under Section 143(3) were initiated by one assessing officer but completed by another without a mandatory transfer order under Section 127. The tribunal disallowed capital gains deductions claimed by the appellant, observing that the transaction documents were self-manufactured, lacking genuine corroborative evidence. The ledger entries and unregistered agreements were deemed insufficient to substantiate the claimed expenses. Consequently, the assessment order was quashed for want of valid jurisdictional assumption, effectively nullifying the tax assessment.
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