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...
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Additions towards unrecorded expenditure - A.O. has disallowed the said expenditure in Note 26 foreign currency transactions, pertaining to purchase of shooting equipment. - As the assessee was unable to furnish any documents or breakup of the said expenses, the A.O. rejected the assessee’s submission that the import transaction has been disclosed in the books of accounts of the assessee and was, therefore, treated as ‘unexplained expenditure’. The assessee has failed to substantiate its claim - Additions confirmed - AT
Additions towards unrecorded expenditure - A.O. has disallowed the said expenditure in Note 26 foreign currency transactions, pertaining to purchase of shooting equipment. - As the assessee was unable to furnish any documents or breakup of the said expenses, the A.O. rejected the assessee’s submission that the import transaction has been disclosed in the books of accounts of the assessee and was, therefore, treated as ‘unexplained expenditure’. The assessee has failed to substantiate its claim - Additions confirmed - AT
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