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...
Reopening of assessment under the new regime requires prior sanction by a specified senior authority where reassessment is sought after three years; if income escaping assessment is below the Rs.50,00,000 threshold, no reassessment notice may be issued after three years. Here the alleged escaped income was Rs.10,25,756 and the notice was issued beyond three years with approval only from the Principal Commissioner, which does not meet the prescribed sanctioning requirement; the ITAT held the section 148 notice and consequent reassessment proceedings invalid and quashed them, allowing the assessee's appeal.
Reopening of assessment under the new regime requires prior sanction by a specified senior authority where reassessment is sought after three years; if income escaping assessment is below the Rs.50,00,000 threshold, no reassessment notice may be issued after three years. Here the alleged escaped income was Rs.10,25,756 and the notice was issued beyond three years with approval only from the Principal Commissioner, which does not meet the prescribed sanctioning requirement; the ITAT held the section 148 notice and consequent reassessment proceedings invalid and quashed them, allowing the assessee's appeal.
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