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 notice under section 148 was unsigned and therefore void ab initio; consequentially the reassessment proceedings and the assessment framed thereon were quashed and unsustainable. The Tribunal found the AO failed to verify the assessee's evidences, did not identify specific defects, and neglected to issue statutory summons under section 133(6) to relevant purchasers; reliance on unexamined assertions rendered the additions unjustified. Investments traced to earlier assessment years, previously accepted by the department, could not be reopened in the year of sale without valid grounds. The appeal of the assessee was allowed and the reassessment order set aside.
ITAT held that the notice under section 148 was unsigned and therefore void ab initio; consequentially the reassessment proceedings and the assessment framed thereon were quashed and unsustainable. The Tribunal found the AO failed to verify the assessee's evidences, did not identify specific defects, and neglected to issue statutory summons under section 133(6) to relevant purchasers; reliance on unexamined assertions rendered the additions unjustified. Investments traced to earlier assessment years, previously accepted by the department, could not be reopened in the year of sale without valid grounds. The appeal of the assessee was allowed and the reassessment order set aside.
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