Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
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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