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...
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Cash is treated as property under the Act, and routing demonetised cash through another person's bank account and back through banking channels can amount to a benami arrangement if the alleged business deal is not genuine. The Tribunal relied on inconsistencies in stock records, invoices, bank entries and the claimed gold sale, and noted the absence of purchaser KYC, PAN and reliable proof of delivery through the broker; it treated the broker's affidavit as insufficient. It also rejected objections on non-examination of the alleged account operator and on cross-examination, finding the person untraceable and no prejudice shown. The attachment was upheld and the appeal dismissed.
Cash is treated as property under the Act, and routing demonetised cash through another person's bank account and back through banking channels can amount to a benami arrangement if the alleged business deal is not genuine. The Tribunal relied on inconsistencies in stock records, invoices, bank entries and the claimed gold sale, and noted the absence of purchaser KYC, PAN and reliable proof of delivery through the broker; it treated the broker's affidavit as insufficient. It also rejected objections on non-examination of the alleged account operator and on cross-examination, finding the person untraceable and no prejudice shown. The attachment was upheld and the appeal dismissed.
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