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...
Bogus LTCG - Addition u/s 68 - onus to prove genuineness of the transactions - The whole basis of making additions is third-party statement and no opportunity of cross-examination has been provided to the assessee to confront these parties. As against this, the assessee’s position that that the transactions were genuine and duly supported by various documentary evidences, could not be disturbed by the revenue. - the additions made by Ld. AO and confirmed by Ld. CIT(A), are not sustainable - AT
Bogus LTCG - Addition u/s 68 - onus to prove genuineness of the transactions - The whole basis of making additions is third-party statement and no opportunity of cross-examination has been provided to the assessee to confront these parties. As against this, the assessee’s position that that the transactions were genuine and duly supported by various documentary evidences, could not be disturbed by the revenue. - the additions made by Ld. AO and confirmed by Ld. CIT(A), are not sustainable - AT
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