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...
Addition of unexplained investments u/s 69B - alleged cash payment for purchase of land - alleged purchase value noted in the diary found in search - it does not contain any information as to what was the cheque amount or cash amount and what was the date of the transaction - on record is a mere noting of the diary which in the absence of any other corroborative evidence cannot be utilized for making addition
Addition of unexplained investments u/s 69B - alleged cash payment for purchase of land - alleged purchase value noted in the diary found in search - it does not contain any information as to what was the cheque amount or cash amount and what was the date of the transaction - on record is a mere noting of the diary which in the absence of any other corroborative evidence cannot be utilized for making addition
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