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...
For unsecured loans under section 68, the note states that the assessee can discharge the onus by producing lender confirmation, PAN, bank statements, salary records and a reply to notice under section 133(6), thereby showing identity, creditworthiness and genuineness of the transaction. On that footing, and because the Revenue produced no contrary material, the addition was said to be unsustainable. It also notes the legal position that, for periods before 01.04.2023, section 68 did not require explanation of the source of source in unsecured-loan cases. The described effect is deletion of the addition, with consequential treatment of MAT credit, interest and penalty initiation issues.
For unsecured loans under section 68, the note states that the assessee can discharge the onus by producing lender confirmation, PAN, bank statements, salary records and a reply to notice under section 133(6), thereby showing identity, creditworthiness and genuineness of the transaction. On that footing, and because the Revenue produced no contrary material, the addition was said to be unsustainable. It also notes the legal position that, for periods before 01.04.2023, section 68 did not require explanation of the source of source in unsecured-loan cases. The described effect is deletion of the addition, with consequential treatment of MAT credit, interest and penalty initiation issues.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
