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...
Validity of reopening of assessment on a non-searched person is examined, focusing on third-party reopening and the mandatory requirement of application of mind. The notice treating the assessee both as searched and non-searched is held to be cursory and devoid of application of mind, and the assessment references an unrelated search without establishing linkage to the search relied upon in the notice. The defective notice and consequent assessment are therefore regarded as resulting from casual drafting, and the challenge to the reopening on that ground is sustained.
Validity of reopening of assessment on a non-searched person is examined, focusing on third-party reopening and the mandatory requirement of application of mind. The notice treating the assessee both as searched and non-searched is held to be cursory and devoid of application of mind, and the assessment references an unrelated search without establishing linkage to the search relied upon in the notice. The defective notice and consequent assessment are therefore regarded as resulting from casual drafting, and the challenge to the reopening on that ground is sustained.
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