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 notices issued u/s 143(2) dated 17/08/2018 and 23/08/2018 were invalid for failing to specify whether scrutiny was "limited" (CASS), "complete" (CASS) or "complete manual" as mandated by the Board format notified 23.06.2017; the CBDT instruction under s.119 is mandatory and binds income-tax authorities. The Tribunal affirmed that the revenue bears the burden to demonstrate strict compliance with the prescribed CASS/notice format and approval procedures. Consequently the assessment order framed u/s 143(3) dated 24/12/2019 was quashed for lack of jurisdiction due to non-compliance with mandatory CBDT instructions.
ITAT held that notices issued u/s 143(2) dated 17/08/2018 and 23/08/2018 were invalid for failing to specify whether scrutiny was "limited" (CASS), "complete" (CASS) or "complete manual" as mandated by the Board format notified 23.06.2017; the CBDT instruction under s.119 is mandatory and binds income-tax authorities. The Tribunal affirmed that the revenue bears the burden to demonstrate strict compliance with the prescribed CASS/notice format and approval procedures. Consequently the assessment order framed u/s 143(3) dated 24/12/2019 was quashed for lack of jurisdiction due to non-compliance with mandatory CBDT instructions.
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