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...
Unexplained money u/s 69A - Unexplained loan - the loan creditors had deposited cash in their accounts and mostly on the very same day they had transferred the same to the assessee’s bank account - there were no significant bank transactions in the bank accounts of the loan creditors. Needless to mention that banking transaction alone will not make the transactions to be genuine. - From the above it is crystal clear that the creditworthiness of the loan creditors is not established. - AT
Unexplained money u/s 69A - Unexplained loan - the loan creditors had deposited cash in their accounts and mostly on the very same day they had transferred the same to the assessee’s bank account - there were no significant bank transactions in the bank accounts of the loan creditors. Needless to mention that banking transaction alone will not make the transactions to be genuine. - From the above it is crystal clear that the creditworthiness of the loan creditors is not established. - AT
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