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...
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A reassessment notice issued beyond three years from the end of the relevant assessment year required prior approval from the higher authority specified under section 151(ii), not the Principal Commissioner. As the sanction was obtained from an incompetent authority, the approval was invalid and contrary to law. The Tribunal treated this defect as fatal and quashed both the reassessment notice and the consequential assessment order.
A reassessment notice issued beyond three years from the end of the relevant assessment year required prior approval from the higher authority specified under section 151(ii), not the Principal Commissioner. As the sanction was obtained from an incompetent authority, the approval was invalid and contrary to law. The Tribunal treated this defect as fatal and quashed both the reassessment notice and the consequential assessment order.
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