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 - unaccounted business receipt - various submissions were filed by the assessee to explain the source but revenue authorities could not go deeper to bring the truth on record. Further Ld. A.O as well as Ld. CIT(A) have observed that it cannot not be denied that the alleged amount is an unaccounted business receipts. In our considered view and in the given facts and circumstances of the case and being fair to both the parties, we treat the alleged cash deposit as unaccounted business receipt and apply net profit rate of 8% on this amount and the same is added to the income of the assessee - AT
Addition u/s 69A - unaccounted business receipt - various submissions were filed by the assessee to explain the source but revenue authorities could not go deeper to bring the truth on record. Further Ld. A.O as well as Ld. CIT(A) have observed that it cannot not be denied that the alleged amount is an unaccounted business receipts. In our considered view and in the given facts and circumstances of the case and being fair to both the parties, we treat the alleged cash deposit as unaccounted business receipt and apply net profit rate of 8% on this amount and the same is added to the income of the assessee - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
