Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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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