Reversal of input tax credit in proportion to exempt supply: specificity of show-cause notice required; order set aside, fresh proceedings allowed wit...
Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
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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