Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Cancellation of a supplier's GST registration, by itself, does not justify treating purchases as non-genuine where the supplier had died, the proprietary business had ceased on that account, and the purchase invoices and transport documents predated the death. The assessee's explanation for the supplier's non-response was accepted, and the Revenue had not identified any discrepancy in the purchases or disputed the corresponding sales. On those facts, disallowance of the purchases and the resulting addition were unjustified and were deleted.
Cancellation of a supplier's GST registration, by itself, does not justify treating purchases as non-genuine where the supplier had died, the proprietary business had ceased on that account, and the purchase invoices and transport documents predated the death. The assessee's explanation for the supplier's non-response was accepted, and the Revenue had not identified any discrepancy in the purchases or disputed the corresponding sales. On those facts, disallowance of the purchases and the resulting addition were unjustified and were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
