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 68 - unsecured loans received - sole reason for confirming the addition was low income tax return in the year of issue whereas it was contended that it is not the case for the subsequent years - the assessee discharge the onus, proved the receipt and repayment of the loan received along with the interest and the same is also been brought before the Assessing Officer during the assessment proceedings. Hence, the reasons given by the revenue authorities for treating the loan amount u/s 68 is factually and legally not valid. - AT
Addition u/s 68 - unsecured loans received - sole reason for confirming the addition was low income tax return in the year of issue whereas it was contended that it is not the case for the subsequent years - the assessee discharge the onus, proved the receipt and repayment of the loan received along with the interest and the same is also been brought before the Assessing Officer during the assessment proceedings. Hence, the reasons given by the revenue authorities for treating the loan amount u/s 68 is factually and legally not valid. - AT
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