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 held that the reassessment order is void ab initio and quashed it in toto. The Tribunal found the impugned order unsigned, rendering it legally ineffective; proceedings were instituted and concluded against a struck-off/defunct company that had ceased to exist; and the addition related to an assessment year unconnected to the subject transaction. These defects, individually sufficient to vitiate the assessment, cumulatively established that the reassessment was a legal nullity. The erstwhile director's age and health-related difficulties in assembling records did not justify sustaining proceedings fundamentally flawed in form and jurisdiction. Consequentially, the reassessment and resultant additions were set aside.
The ITAT held that the reassessment order is void ab initio and quashed it in toto. The Tribunal found the impugned order unsigned, rendering it legally ineffective; proceedings were instituted and concluded against a struck-off/defunct company that had ceased to exist; and the addition related to an assessment year unconnected to the subject transaction. These defects, individually sufficient to vitiate the assessment, cumulatively established that the reassessment was a legal nullity. The erstwhile director's age and health-related difficulties in assembling records did not justify sustaining proceedings fundamentally flawed in form and jurisdiction. Consequentially, the reassessment and resultant additions were set aside.
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