Legal & Evidentiary Value of GST Assessment Based on Mobile Data and Whatsapp Chat
I. Introduction:
In today’s business environment, the use of digital platforms such as WhatsApp and similar messaging applications for commercial communication has become widespread, particularly among small and medium enterprises (SMEs). These platforms are often used for placing orders, confirming dispatch or receipt of goods, receipt of invoice and sharing payment details, owing to their speed, convenience, and ease of use.
However, such informal communication channels pose significant legal and fiscal risks. During inspection, search, or seizure proceedings under tax laws, officers commonly seize mobile phones and electronic devices of the owners and staff. On examination, these devices often reveal chats, digital notes, estimates and other records evidencing business transactions with suppliers and customers. Tax Authorities frequently treat such data as suppression forming the basis for assessments or reassessments, which may lead to substantial tax demands and serious legal consequences for the taxpayer.
In the present article, an endeavour has been made to critically examine the legality, evidentiary admissibility, and sustainability of assessments framed under the Goods and Services Tax (GST) law on the basis of WhatsApp chats and other informal digital records unearthed during search and seizure proceedings conducted by the tax authorities.
II. Legal provisions related to the seizure under GST:
Section 67 empowers the GST officer to search and seize such goods, documents or books or things. The legal provision of the section 67(2) is reproduced below:
(2) Where the proper officer, not below the rank of Joint Commissioner, either pursuant to an inspection carried out under sub-section (1) or otherwise, has reasons to believe that any goods liable to confiscation or any documents or books or things, which in his opinion shall be useful for or relevant to any proceedings under this Act, are secreted in any place, he may authorise in writing any other officer of central tax to search and seize or may himself search and seize such goods, documents or books or things:
Provided that where it is not practicable to seize any such goods, the proper officer, or any officer authorised by him, may serve on the owner or the custodian of the goods an order that he shall not remove, part with, or otherwise deal with the goods except with the previous permission of such officer:
Provided further that the documents or books or things so seized shall be retained by such officer only for so long as may be necessary for their examination and for any inquiry or proceedings under this Act.
Thus, the mobile phones, electronic devices, etc., are seized on the pretext of being covered under the ‘things’ or ‘documents’ by the tax department.
III. Restrictions and Privacy Issues on Mobile Phones/Personal Devices:
It is a settled legal position that no statute can override the Fundamental Rights guaranteed under the Constitution of India. The seizure of mobile phones constitutes an infringement of the fundamental right to privacy protected under Article 21, as affirmed in Justice K.S. Puttaswamy (Retd.) & Anr. v. Union of India & Ors., (2017) 10 SCC 1. Considering that mobile devices contain highly personal and confidential data, such seizure during search and seizure proceedings is unwarranted, illegal, and violative of constitutional safeguards.
But at the same time, there is no denying the fact that most of the business information nowadays is exchanged on WhatsApp or other messaging applications. So, such business information is likely to be stored in the mobile phones of the owner and employees. In the absence of any express bar under the GST law to confiscate a mobile phone, the tax authority, to unearth suppression etc., is bound to seize the mobile phones and other electronic devices.
IV. Compelling password disclosure post-seizure is self-incrimination?
Once the tax department seizes a mobile phone, it requires the owner to disclose the password to access its contents. A question arises as to whether disclosing a password to the tax authorities amounts to self-incrimination. This matter came up for consideration before the Hon’ble Karnataka High Court in case of Virendra Khanna vs. State of Karnataka (in WP No. 11759 of 2020, judgment dated 12.3.2021) where Court hold that providing password to a mobile/electronic device, after a search warrant, neither tantamount to ‘self-incrimination’ under article 20(3) nor can be considered a violation of right to privacy and thus is not constitutionally invalid.
V. Admissibility & evidentiary value:
WhatsApp messages are classified as “electronic records” and their admissibility in Indian courts is governed by Section 65B of the Indian Evidence Act, 1872 (now Section 63 of the Bharatiya Sakshya Adhiniyam, 2023) and the Information Technology Act, 2000. Further, section 145 of the CGST Act,2017, also laid down criteria for the admissibility of such electronic records.
Let us decipher the legal provisions to understand the matter with more clarity.
A. Under the GST law:
Section 145 – Admissibility of micro films, facsimile copies of documents and computer printouts as documents and as evidence
(1) Notwithstanding anything contained in any other law for the time being in force,-
(a) a micro film of a document or the reproduction of the image or images embodied in such micro film (whether enlarged or not); or
(b) a facsimile copy of a document; or
(c) a statement contained in a document and included in a printed material produced by a computer, subject to such conditions as may be prescribed; or
(d) any information stored electronically in any device or media, including any hard copies made of such information,
shall be deemed to be a document for the purposes of this Act and the rules made thereunder and shall be admissible in any proceedings thereunder, without further proof or production of the original, as evidence of any contents of the original or of any fact stated therein of which direct evidence would be admissible.
(2) In any proceedings under this Act or the rules made thereunder, where it is desired to give a statement in evidence by virtue of this section, a certificate,-
(a) identifying the document containing the statement and describing the manner in which it was produced;
(b) giving such particulars of any device involved in the production of that document as may be appropriate for the purpose of showing that the document was produced by a computer,
A careful perusal of the above provision of section 145 makes it clear that this section starts with a non-obstante clause, meaning thereby that it has an overriding effect over any law for the time being in force. This section addresses how specific information, such as electronic records or statements, can be used as evidence under the GST law. It allows digital evidence to be treated as valid in GST investigations and proceedings, given that it is properly authenticated and relevant to the case.
An original electronic record, such as a hard disk, pen drive, or mobile data, serves as primary evidence and is more easily admissible. Copies, printouts, or records from cloud storage are considered secondary evidence, and to be admissible as evidence under the law, they must be accompanied by a certificate as stated under sub-section (2) of section 145.
B. Under the Central Excise law:
The requirement of getting a certificate is not a new requirement under the GST law. Rather, the same was also mandated under Section 36B of the Central Excise Act,1944. The relevant provisions under the erstwhile law are reproduced for the sake of brevity.
36B. Admissibility of microfilms, facsimile copies of documents and computer printouts as documents and as evidence
(4) In any proceedings under this Act and the rules made thereunder, where it is desired to give a statement in evidence by virtue of this section, a certificate doing any of the following things, that is to say,—
(a) identifying the document containing the statement and describing the manner in which it was produced;
(b) giving such particulars of any device involved in the production of that document as may be appropriate for the purpose of showing that the document was produced by a computer;
(c) dealing with any of the matters to which the conditions mentioned in sub-section (2) relate, and purporting to be signed by a person occupying a responsible official position in relation to the operation of the relevant device or the management of the relevant activities (whichever is appropriate) shall be evidence of any matter stated in the certificate; and for the purposes of this sub-section it shall be sufficient for a matter to be stated to the best of the knowledge and belief of the person stating it.
The above legal provisions for admissibility of electronic records, computer printouts, etc., under the erstwhile law are more detailed and comprehensive vis-à-vis section 145 of the CGST Act,2017. Further, the criteria of obtaining a certificate under sub-section (4) of section 36B of the Central Excise Act,1944, are also in a similar line as those laid down u/s 145(2) of the CSGT Act,2017. However, the objective under both the law remains the same, i.e. to treat such electronic or reproduced documents as admissible evidence without requiring original documents.
C. Under the Evidence Act:
Section 145 of the CGST Act, 2017, and Section 36B of the Central Excise Act, 1944, both codify the admissibility of electronic records such as microfilms, facsimile copies, and computer printouts as evidence. They require a certificate authenticating the electronic document’s genuineness, closely reflecting the mandatory certification under Section 65B of the Indian Evidence Act (now Section 63 of the Bharatiya Sakshya Adhiniyam, 2023). These provisions legally integrate the Indian Evidence Act’s standards into GST and Central Excise laws, ensuring electronic evidence is valid in tax proceedings only when accompanied by proper certification. This harmonizes evidentiary requirements across tax statutes and evidence law.
The relevant provisions of section 65B of the Indian Evidence Act,1972, are reproduced as under:
65B. Admissibility of electronic records
(4) In any proceedings where it is desired to give a statement in evidence by virtue of this section, a certificate doing any of the following things, that is to say, —
(a) identifying the electronic record containing the statement and describing the manner in which it was produced;
(b) giving such particulars of any device involved in the production of that electronic record as may be appropriate for the purpose of showing that the electronic record was produced by a computer;
(c) dealing with any of the matters to which the conditions mentioned in sub-section (2) relate,
and purporting to be signed by a person occupying a responsible official position in relation to the operation of the relevant device or the management of the relevant activities (whichever is appropriate) shall be evidence of any matter stated in the certificate; and for the purposes of this sub-section it shall be sufficient for a matter to be stated to the best of the knowledge and belief of the person stating it.
The above provisions of section 65B of the Evidence Act are far more detailed and comprehensive vis-à-vis section 145 of the CGST Act and section 36B of the Central Excise Act. It appears that the provisions of section 65B are the mother provisions based upon which the statutory provisions of section 145 (CGST) and section 36B (Central Excise) are framed. Thus, the mandatory requirement of a certificate authenticating the electronic record’s origin, integrity, and reliability is sine qua non for admissibility as evidence under the law.
D. Under Bharatiya Sakshya Adhiniyam:
Section 63 of Bharatiya Sakshya Adhiniyam, 2023, deals with the admissibility of electronic records. Sub-section (4) of the said provision is as follows:
“(4) In any proceeding where it is desired to give a statement in evidence by virtue of this section, a certificate doing any of the following things shall be submitted along with the electronic record at each instance where it is being submitted for admission, namely,
(a)………………………….
(b)…………………………..
(c) ……………………………..
and purporting to be signed by a person in charge of the computer or communication device or the management of the relevant activities (whichever is appropriate) and an expert shall be evidence of any matter stated in the certificate; and for the purposes of this sub-section it shall be sufficient for a matter to be stated to the best of the knowledge and belief of the person stating it in the certificate specified in the Schedule.
Thus, section 63, which is pari-materia to section 65B of the Indian Evidence Act,1972, also covers within its sweep an expert’s certificate which is mandatory. This is an extra requirement under the new law.
E. Under the Information Technology Act
4. Legal recognition of electronic records.
Where any law provides that information or any other matter shall be in writing or in the typewritten or printed form, then, notwithstanding anything contained in such law, such requirement shall be deemed to have been satisfied if such information or matter is–
(a) rendered or made available in an electronic form; and
(b) accessible so as to be usable for a subsequent reference.
Thus, section 4 of The Information Technology Act,2000, also provides Legal recognition of electronic records, giving electronic data the same validity as paper documents where the law requires information in writing.
VI. Analysis of the above legal provisions with some judicial precedents:
WhatsApp chats recovered during a search and seizure may appear in the form of text, images, voice recordings, videos, or any other format. Regardless of the form, such material constitutes digital or electronic evidence under the GST law, and its printouts are treated as documentary evidence. Thus, to be admissible as evidence under the GST law, it is mandatory under sub-section (2) of Section 145, which requires issuance of a certificate on this behalf by a person occupying the responsible official position in relation to the operation of the relevant device. Such a certificate, and for the purpose of the subsection, shall be sufficient for a matter to be stated to the best of the knowledge and the belief of the persons stating it.
As discussed above, Section 145 of the CGST Act,2017, is pari materia to Section 36B of the Central Excise Act, 1944 and Section 65B of the erstwhile Indian Evidence Act, 1872, and Section 63 of the Bhartiya Sakshya Adhiniyam, 2023. The Hon’ble Supreme Court in the case of Anvar P.V. Vs. P.K. Basheer – 2017 (352) ELT 416 (SC), held that any documentary evidence by way of an electronic record under the Evidence Act can be proved only in accordance with the procedure prescribed under Section 65B. Section 65B(4) of the Evidence Act specifies that to present an electronic record as a statement in any proceedings, the following conditions must be met:
(a) A certificate identifying the electronic record containing the statement must be provided;
(b) The certificate must describe how the electronic record was produced;
(c) The certificate must provide details of the device involved in producing that record;
(d) The certificate must address the conditions mentioned in Section 65B(2) of the Evidence Act;
(e) The certificate must be signed by a person in a responsible official position related to the operation of the relevant device.
[Para 14]
The Evidence Act does not contemplate or permit the proof of an electronic record by oral evidence if requirements under Section 65B of the Evidence Act are not complied with, as the law now stands in India.
[Para 17]
It was further held that, such a certificate must accompany the electronic record like computer printout, Compact Disc (CD), Video Compact Disc (VCD), pen drive, mobile data, etc., pertaining to which a statement is sought to be given in evidence, when the same is produced in evidence and that the person need to state in the certificate that the same is to the best of his knowledge and belief. All these safeguards are taken to ensure the source and authenticity, which are the two hallmarks pertaining to the electronic record sought to be used as evidence. Electronic records being more susceptible to tampering, alteration, transposition, excision, etc., without such safeguards, the whole trial based on proof of electronic records can lead to a travesty of justice.
In GST search cases, though a seizure memo of the mobile phone and electronic devices is provided by the seizing officers, but certificate as contemplated u/s 145(2) of the CGST Act, read with section 65B of the Evidence Act, is not commonly obtained. This resulted in the violation of the mandatory condition laid down u/s 145(2) of the Act, and Courts have taken a consistent view that such evidence is not admissible under the law. It is pertinent to mention the following judicial precedents:
- In the case of A2Z Infraservices Ltd. v. Quippo Infrastructure Ltd.(now Viom Infra Ventures Ltd.), SLP(C) No. 8636 of 2021, decided on July 14, 2021, the Hon’ble Supreme Court clarified the evidentiary value of WhatsApp chats. The Court find that the complexities arise as only the printouts of the conversations may be presented in court, the nature of WhatsApp chats is largely secondary. However, the Indian Evidence Act requires that any “electronic record” be presented in the main form of evidence or that the document be proven by primary evidence before it may be admitted as evidence.
A bench of Hon’ble Chief Justice N V Ramana and Hon’ble Justice A S Bopanna, and Hon’ble Justice Hrishikesh Roy said-
“What is the evidential value of WhatsApp messages these days? Anything can be created and deleted on social media these days. We don’t attach any value to the WhatsApp messages.”
“Prima facie we are not satisfied with the HC direction for depositing the money in an escrow account. We are not considering the purported admission in WhatsApp messages. If it is not late, then go before the arbitrator and parties would be bound by the arbitrator’s award.”
-Issue of abetment of misdeclaration under Customs – issue of admissibility of incriminating WhatsApp chat messages from the relevant mobiles
-The appellant argued that if the WhatsApp messages are required to be used as evidence, a certificate certifying, identifying the WhatsApp messages and describing the manner in which it was produced, giving particulars of the cell phone involved in the production of the WhatsApp messages, to show that the WhatsApp messages were regularly supplied to the said cell phone, the cell phone was operating properly during the message period involved.
-On this point, the CESTAT held:
-“We are of the view that retrieval of the data from the mobile phone of a person is as good as taking out a data printout from a hard disk of a computer. We are therefore of the view that the procedure laid down under Section 138C of the Customs Act, which is pari materia with Section 145 of the CGST Act, should have been followed. Since the procedure as mentioned above has not been followed by the Adjudicating Authority, it loses its evidentiary value.”
- Hon’ble Orrisa High Court in the case of Commissioner of Central Excise and Customs, Bhubaneswar-II Versus Shivam Steel Corporation reported in (2023) 2 Centax 259 (Ori.) held that without a certificate as mandated under section 36B(4) of the CE Act, accompanying the computer print-out, it cannot be relied upon by the Department in the adjudication proceedings. (para 18);
- Hon’ble Delhi High Court in the case of Commr. of Central Excise, Delhi-1 Versus Jindal Nickel & Alloys Ltd. reported in 2020 (371) E.L.T. 661 (Del.) held that the Provisions of Section 36B of the Central Excise Act, 1944 are mandatory and to be complied with before admitting computer printouts as evidence. (paras 15, 16);
- Hon’ble Calcutta Tribunal in the case of Prinik Steels Pvt Ltd v. Commissioner of Central Excise, Customs and ST, Bhubaneswar- I Excise Appeal Nos. 533-536 of 2010, CESTAT Kolkata [2024] 160 taxmann.com 81 (Kolkata – CESTAT) held that Section 65B of the Evidence Act is pari materia with Section 36B of the Central Excise Act, 1944. Unless the conditions of Section 65B(2) of the Evidence Act, which is pari materia with Section 36B(4) of the Central Excise Act, are complied with, no reliance can be placed on any computer printouts. Admittedly, the procedure set out in Section 36B has not been followed in this case. It was held that the data retrieved from the computer printout alone cannot be relied upon to demand duty without any corroborating evidence. (paras 12.5, 12.6);
A perusal of the above rulings, supported by various other precedents, one may summarize the following principles developed over the years:
(i) WhatsApp messages alone are not conclusive evidence in the absence of any supporting corroborative evidence.
(ii) WhatsApp chats, being electronic records, are admissible as evidence, but they must comply with the mandatory conditions of Section 145 (2) of the CGST Act,2017, read with Section 65B of the Indian Evidence Act, 1872.
(iii) WhatsApp messages have weak evidentiary value without proof, as anything can be created and deleted on social media these days, and their meaning must be proved through formal trial and cross-examination.
(iv) In cases where WhatsApp chats were general or non-specific, courts have rejected them as a basis for assessment.
(v) Assessments based on chats found on a third party’s phone are not tenable in the absence of independent evidence linked the assessee to the transactions.
VII. Transforming judicial perspective:
Some of the recent Court’s ruling marks a new development in the use of digital evidence in taxation matters. It makes clear that even encrypted or informal messages can be examined and used against a person if they are legally obtained and supported by other confirming evidence. The requirement of obtaining a certificate u/s 65B at the adjudication level is dispensed with in cases where clinching evidence or corroborative tangible materials are available on record. Let us discuss some more recent judicial rulings to understand the matter further.
- The Rajasthan High Court in the landmark case of Giriraj Pugalia Vs. Assistant Commissioner of Income Tax, Circle-1, Income Tax Department, Bikaner, in the writ petition number-2025: RJ-JD:14017-DB, WP 3152/2025 vide its judgement dated: 04.03.2025 held that
14. This Court observes that the law regarding Section 153C of the Act of 1961 has a foundation of the search and seizure impact, the ‘other person’ and the record of the present case clearly indicates that the WhatsApp chat is completely corroborated, and the said Chat which could be considered to be falling in the definition of other documents totally corroborated by the specific transactions which have taken place regarding the assessee viz. petitioner-Giriraj Pugalia, Proprietor of M/s. Ratan Industries, who had clearly purchased the plots No. SP 818-(II)-3 & 818-(II)-4 from the Om Kothari Group; such sale and purchase is directly established with specific information in a particular year, whereas it has not been shown by the assessee and thus, the power under Section 153C of the Act of 1961 has been rightly exercised by the respondent in the present case.
15. The persons having the WhatsApp chats were connected with both the companies herein and the transactions were regarding specific plots and the details of cash payment were clearly contained in the WhatsApp chat, thus, with such specific inputs, the same cannot be said to be vague or hit by the strict parameters of Section 153C of the Act of 1961.
In this significant ruling, the Rajasthan High Court upheld the issuance of notice under Section 153C of the Income Tax Act based on WhatsApp chats and corroborative digital evidence found during a search on Om Kothari Group. The Court observed that specific plots, amounts, and transactions involving cash payments were reflected in both the chats and corroborated by digital data and a satisfaction note. The Court held that when information is specific, corroborated, and transaction-based, it is sufficient for invoking Section 153C—even if it originates from digital evidence like WhatsApp messages.
By accepting WhatsApp chats as valid evidence in income tax cases, the court has shown that the legal system is willing to update old rules to fit today’s digital world. This confirms that even informal talks can lead to serious legal and financial issues if they show wrongdoing. The ruling also strengthens the powers of investigators while protecting individual rights, balancing the needs of law enforcement with fair procedure.
- In Assistant Commissioner of Income-tax v. Vetrivel Minerals (VV Minerals) [2025] 174 taxmann.com 110 (Madras), the question that came before the Division Bench of the Hon’ble Madras High Court was whether the non-obtaining of a certificate under the Evidence Act (now BSA) will vitiate the assessment proceedings?
The Hon’ble Court held that Section 65B of the Evidence Act, 1872, as well as Section 63 of Bharatiya Sakshya Adhiniyam, 2023, are inapplicable to the assessment proceedings before the assessing officer/appellate authority/tribunal. Section 1 of the Indian Evidence Act, 1872, makes it clear that its provisions apply to all judicial proceedings in or before any court. Section 1 of BSA is also on the same lines. They do not say anywhere that they would apply to quasi-judicial proceedings. When the statutory law does not mandate the applicability of Section 65B (corresponding to Section 63 of BSA) and when the Hon’ble Supreme Court has been repeatedly holding that the income tax authorities are not bound by the strict rules of evidence, the learned single Judge could not have held that Section 65B of the Evidence Act is applicable. Thus, the conclusion drawn by the single judge was held patently erroneous.
[Para 14]
It was further clarified by the Hon’ble Court that it is open to the assessee to challenge the genuineness of the material relied on by the department. But the non-furnishing of the certificate under Section 65B cannot be used as a shield to resist the reception of the electronic record. This is for the simple reason that the assessment proceedings are not judicial proceedings and the technical rules of the Evidence Act are inapplicable to them. There is yet another reason. The adverse materials have been seized from the electronic systems and instruments maintained by the assessee/their employees. It would be too much to expect them to issue certificates in favour of the department that would use the material against them.
VIII. Scenario under the GST law:
For GST assessment and adjudication proceedings, the statutory framework under the CGST Act itself provides for the admissibility of electronic records, and the strict procedural requirements of Section 65B of the Indian Evidence Act or Section 63 of the BSA (such as the mandatory certificate under Section 65B (4) are not always insisted upon. However, in cases where GST proceedings are challenged before Courts (not just adjudicating authorities), the requirements of Section 65B or Section 63 may become relevant for the admissibility of electronic evidence.
The taxable event under GST is the supply of goods or services made in the course or furtherance of business for a consideration, which triggers the liability to pay GST. Further, section 9 prescribes the mechanism for the levy and collection of GST. Thus, until and unless a transaction qualifies to be a supply and falls within the four walls of sections 7 and 9, no GST can be levied.
Data extracted from mobile phones, WhatsApp chats, and messages is though admissible evidence; however, such data must be corroborated by relevant supporting materials. While the tax department may initiate proceedings based on this data, the final conclusion depends on the entirety of the material evidence gathered. For example, let us assume the tax department extracted some pictures of estimates/ slips from the taxpayer’s mobile phone. Now, to conclude such slips as a supply transaction under GST, it needs to be established first who was the author of such slips, how the goods mentioned in such slips were transported/delivered/dispatched, what was the source of goods supplied, to whom such goods were delivered, how the sales consideration was derived, how the transactions stated were executed, etc. etc. In this process, it is compulsory to examine all the parties to the purported transactions, viz., the recipient, transporter, staff, etc. Thus, until and unless such an examination is done, mere extraction of data from a mobile phone or admission by the owner in his statement per se cannot be grounds to consider the transaction as a supply. Further admission, if any, made by the owner/staff in their statement is also subject to the relevancy test laid down u/s 136 of the CGST Act,2017. Thus, unlike the Income Tax law, under GST, a mere receipt cannot be considered as ‘supply’ until and unless clinching evidence of actual supply is placed on record.
The Supreme Court in CBI v. V. C. Shukla [1998] 3 SCC 410 (Jain Hawala Case) held that vague or tenuous entries in loose sheets do not constitute legal evidence unless corroborated by corresponding entries in regular books of account of both parties. It clarified that a “book” means a bound collection of sheets, and loose papers are not admissible under Section 34 of the Indian Evidence Act. Furthermore, entries in books alone are insufficient to establish liability; independent and trustworthy evidence is required to substantiate the truthfulness of such entries before fixing liability. Thus, the Court emphasized corroboration beyond mere account entries to prove liability.
The above view further gathers reinforcement from the judgment of the Hon’ble Supreme Court in the case of Common Cause v. UOI, [2017] 77 taxmann.com 245, popularly known Sahara diaries and Aditya Birla diaries case.
IX. Concluding remarks:
In conclusion, it can be said that the growing reliance on digital communication has introduced new evidentiary dimensions in tax assessments. While WhatsApp chats can offer valuable insight into commercial intent and transaction traces, they must be corroborated with supporting documents and proper verification to ensure fairness and legal soundness. The govt. armed tax authorities under the new Income Tax Act, 2025, with legal power to access and use information from sources such as WhatsApp chats, social media accounts, and emails as evidence for tax assessments and investigations, effective from April 1, 2026. This evolving interplay between technology and tax law underscores the importance of prudent documentation, transparency, and procedural integrity in GST administration also.
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Disclaimer: The above views are compiled by the author based on the study of various legal provisions, judicial pronouncements, etc. There may be some other views also on this subject matter. So, the readers are requested to refer to relevant provisions of the statute, latest judicial pronouncements, circulars, clarifications, etc., of the respective law and obtain legal opinion before acting on the above write-up.
The author is a practicing Chartered Accountant at Guwahati and can be reached at: manoj_nahata2003@yahoo.co.in.
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