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...
Recorded purchases supported by bills and vouchers, transport and FASTag data, banking-channel payments, and GST/TDS particulars were treated as genuine where the books were not rejected and no defect appeared in trading results or stock records. Reliance on a supplier's statement without effective cross-examination was insufficient. The source of expenditure principle was applied to state that unexplained expenditure provisions cannot be invoked merely because the supplier's authenticity is doubted when the payment source is explained from disclosed accounts. On these facts, the addition for alleged bogus purchases was deleted and the Revenue challenge failed.
Recorded purchases supported by bills and vouchers, transport and FASTag data, banking-channel payments, and GST/TDS particulars were treated as genuine where the books were not rejected and no defect appeared in trading results or stock records. Reliance on a supplier's statement without effective cross-examination was insufficient. The source of expenditure principle was applied to state that unexplained expenditure provisions cannot be invoked merely because the supplier's authenticity is doubted when the payment source is explained from disclosed accounts. On these facts, the addition for alleged bogus purchases was deleted and the Revenue challenge failed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
