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...
In completed or unabated assessments under section 153A, additions are confined to incriminating material found during the search; material already available with the Revenue, such as the HSBC Geneva Base Note, cannot by itself support an addition. Applying that rule, the article notes that the additions for the relevant year were unsustainable because no incriminating search material linked to them was found. On section 69A, the threshold requirement is proof that the assessee owned the money or asset; where the foreign accounts stood in third-party names and the Revenue could not prove ownership, the additions were properly deleted.
In completed or unabated assessments under section 153A, additions are confined to incriminating material found during the search; material already available with the Revenue, such as the HSBC Geneva Base Note, cannot by itself support an addition. Applying that rule, the article notes that the additions for the relevant year were unsustainable because no incriminating search material linked to them was found. On section 69A, the threshold requirement is proof that the assessee owned the money or asset; where the foreign accounts stood in third-party names and the Revenue could not prove ownership, the additions were properly deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
