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 dismissed revenue's appeal in reassessment proceedings u/s 147. Despite AO treating assessee's return as non-est due to lack of e-verification, AO computed assessed income from returned income, indicating cognizance of the return. Assessee rectified e-verification defect immediately upon notification. AO failed to issue mandatory notice u/s 143(2) and furnish reasons for reopening assessment, constituting jurisdictional defects not curable u/s 292BB. ITAT held these procedural failures fatal to reassessment proceedings, relying on Hotel Blue Moon and CIT vs Trend Electronics precedents establishing that absence of s.143(2) notice invalidates assumption of jurisdiction and non-furnishing of reopening reasons renders reassessment proceedings void. Reassessment proceedings quashed.
ITAT dismissed revenue's appeal in reassessment proceedings u/s 147. Despite AO treating assessee's return as non-est due to lack of e-verification, AO computed assessed income from returned income, indicating cognizance of the return. Assessee rectified e-verification defect immediately upon notification. AO failed to issue mandatory notice u/s 143(2) and furnish reasons for reopening assessment, constituting jurisdictional defects not curable u/s 292BB. ITAT held these procedural failures fatal to reassessment proceedings, relying on Hotel Blue Moon and CIT vs Trend Electronics precedents establishing that absence of s.143(2) notice invalidates assumption of jurisdiction and non-furnishing of reopening reasons renders reassessment proceedings void. Reassessment proceedings quashed.
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