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...
Addition u/s.69A r/w Sec. 115BBE - unexplained cash found during search - Locker was last operated on 29.10.2015. The fact that the locker has not been operated in the assessment year 2017 -18 is before the revenue authorities. Hence, the amount deemed to have been undisclosed income for the assessment year 2016-17 whereas the amount has been brought to tax for the assessment year 2017 -18. Hence, the addition made in the AY 2017-18 cannot be upheld. - AT
Addition u/s.69A r/w Sec. 115BBE - unexplained cash found during search - Locker was last operated on 29.10.2015. The fact that the locker has not been operated in the assessment year 2017 -18 is before the revenue authorities. Hence, the amount deemed to have been undisclosed income for the assessment year 2016-17 whereas the amount has been brought to tax for the assessment year 2017 -18. Hence, the addition made in the AY 2017-18 cannot be upheld. - AT
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