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...
Whether a Jurisdictional Assessing Officer (JAO) can initiate proceedings under Sections 148A and 148 after implementation of the Faceless Scheme: relying on precedent that post- Faceless Scheme initiation and issuance of notices by the JAO is ultra vires and per se illegal, the court held such notices and consequential assessments unsustainable; therefore the impugned notices under Sections 148A/148 and all orders flowing therefrom are quashed. Relief is granted on jurisdictional grounds, while liberty is reserved to the revenue to pursue further action as indicated by the court. - HC
Whether a Jurisdictional Assessing Officer (JAO) can initiate proceedings under Sections 148A and 148 after implementation of the Faceless Scheme: relying on precedent that post- Faceless Scheme initiation and issuance of notices by the JAO is ultra vires and per se illegal, the court held such notices and consequential assessments unsustainable; therefore the impugned notices under Sections 148A/148 and all orders flowing therefrom are quashed. Relief is granted on jurisdictional grounds, while liberty is reserved to the revenue to pursue further action as indicated by the court. - HC
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