Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
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.
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