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 under section 41(1) - Scope of abated assessment - Onus to prove - Even before the Bench, the ld Counsel fails to submit the basic document, bank statement, therefore it is not possible for the Bench to find the fact that whether payment has been made by account payee cheques or non-account payee cheques. The ld Counsel also argues that in assessment year 2011-12, the assessing officer cannot make addition without the aid of incriminating material. We note that assessment year 2011-12 is an abated assessment where assessing officer can do regular scrutiny, hence plea raised by the ld Counsel is not acceptable. - AT
Addition under section 41(1) - Scope of abated assessment - Onus to prove - Even before the Bench, the ld Counsel fails to submit the basic document, bank statement, therefore it is not possible for the Bench to find the fact that whether payment has been made by account payee cheques or non-account payee cheques. The ld Counsel also argues that in assessment year 2011-12, the assessing officer cannot make addition without the aid of incriminating material. We note that assessment year 2011-12 is an abated assessment where assessing officer can do regular scrutiny, hence plea raised by the ld Counsel is not acceptable. - AT
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TaxTMI 
TaxTMI 
of 4918 
