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 assessment framed u/s 153C r.w.s. 153A was invalid. The AO of the searched person had factually misattributed seized mobile content to the assessee and forwarded a consolidated satisfaction note covering multiple AYs; the AO of the assessee impermissibly adopted that flawed note and relied on extraneous material (appraisal report, portal data, third-party statements) instead of forming an independent year-wise satisfaction confined to the seized material. Following precedent from Karn. HC, a consolidated satisfaction vitiates jurisdiction. Consequentially the assumption of jurisdiction and assessments under s.153C are void ab initio.
ITAT held that the assessment framed u/s 153C r.w.s. 153A was invalid. The AO of the searched person had factually misattributed seized mobile content to the assessee and forwarded a consolidated satisfaction note covering multiple AYs; the AO of the assessee impermissibly adopted that flawed note and relied on extraneous material (appraisal report, portal data, third-party statements) instead of forming an independent year-wise satisfaction confined to the seized material. Following precedent from Karn. HC, a consolidated satisfaction vitiates jurisdiction. Consequentially the assumption of jurisdiction and assessments under s.153C are void ab initio.
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