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 dominant issue was whether the limitation for passing the final assessment order in a DRP case is governed by section 153(1) read with section 153(4) or by section 144C(13). Relying on coordinate bench precedent that followed HC rulings, the Tribunal held that statutory limitation must be computed under section 153(1) r/w section 153(4), fixing the last permissible date as 30.09.2021. Since the final assessment order was passed on 07.07.2023, it was held to be time-barred and was quashed, resulting in allowance of the taxpayer's appeal. - ITAT
The dominant issue was whether the limitation for passing the final assessment order in a DRP case is governed by section 153(1) read with section 153(4) or by section 144C(13). Relying on coordinate bench precedent that followed HC rulings, the Tribunal held that statutory limitation must be computed under section 153(1) r/w section 153(4), fixing the last permissible date as 30.09.2021. Since the final assessment order was passed on 07.07.2023, it was held to be time-barred and was quashed, resulting in allowance of the taxpayer's appeal. - ITAT
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