Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Admissibility of electronic evidence: The Tribunal held that digital images reproduced in the assessment order lacked requisite legal sanctity because the s.65B certificate and CBDT Manual protocols were not complied with - no officer's attestation of seizure, no documented chain of custody, absence of device identifiers (IMEI) linkage to hash values, and no proof that master/working copies analyzed matched the certified hashes. For failure to establish proper custody, provenance and evidentiary parity under s.65B and forensic guidelines, the electronic evidence was treated as unverifiable and inadmissible; grounds challenging the additions were allowed. - ITAT
Admissibility of electronic evidence: The Tribunal held that digital images reproduced in the assessment order lacked requisite legal sanctity because the s.65B certificate and CBDT Manual protocols were not complied with - no officer's attestation of seizure, no documented chain of custody, absence of device identifiers (IMEI) linkage to hash values, and no proof that master/working copies analyzed matched the certified hashes. For failure to establish proper custody, provenance and evidentiary parity under s.65B and forensic guidelines, the electronic evidence was treated as unverifiable and inadmissible; grounds challenging the additions were allowed. - ITAT
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