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 - Unexplained cash deposits - The assessee’s contention that the loan has been repaid as he could not buy the residential property due to some unavoidable reasons is found to be genuine and reasonable cause. A.O. has not made any verification of the repayment of loan. In our considered view, the A.O. has made huge verification on small time assessees, many of them are seen to be agriculturists in a small village. - Assessee has filed confirmation from all the parties - Additions deleted - AT
Addition u/s 68 - Unexplained cash deposits - The assessee’s contention that the loan has been repaid as he could not buy the residential property due to some unavoidable reasons is found to be genuine and reasonable cause. A.O. has not made any verification of the repayment of loan. In our considered view, the A.O. has made huge verification on small time assessees, many of them are seen to be agriculturists in a small village. - Assessee has filed confirmation from all the parties - Additions deleted - AT
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