Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Electronic material used in search assessments must be shown to be genuine, properly preserved, and supported by a reliable chain of custody; the Tribunal treated the Revenue's failure to record complete device particulars, hash values, and proper certification of later extraction as fatal to reliance on SMS, WhatsApp images, and software screenshots. It also held that approval under section 153D is a statutory safeguard requiring conscious application of mind to each assessment year, not a mechanical signature. Because the assessments rested on inadmissible electronic material and the approval process showed no real scrutiny, the Tribunal quashed the assessments and allowed the assessee's appeals.
Electronic material used in search assessments must be shown to be genuine, properly preserved, and supported by a reliable chain of custody; the Tribunal treated the Revenue's failure to record complete device particulars, hash values, and proper certification of later extraction as fatal to reliance on SMS, WhatsApp images, and software screenshots. It also held that approval under section 153D is a statutory safeguard requiring conscious application of mind to each assessment year, not a mechanical signature. Because the assessments rested on inadmissible electronic material and the approval process showed no real scrutiny, the Tribunal quashed the assessments and allowed the assessee's appeals.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
