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...
Revision u/s 254 - NP estimation on turnover - Bogus bills for purchase of diamonds - it is nothing, but a bogus claim of expenditure recorded in the books of accounts of the assessee against which no revenue towards turnover could be attributed. Therefore, estimation cannot be made on the bogus purchases at 8 or 10 % as claimed by the assessee and the entire bogus claim of expenditure has to be disallowed - AT
Revision u/s 254 - NP estimation on turnover - Bogus bills for purchase of diamonds - it is nothing, but a bogus claim of expenditure recorded in the books of accounts of the assessee against which no revenue towards turnover could be attributed. Therefore, estimation cannot be made on the bogus purchases at 8 or 10 % as claimed by the assessee and the entire bogus claim of expenditure has to be disallowed - AT
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