Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
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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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