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 - on the amounts received as loan, assessee had paid interest and had also deducted TDS on the interest paid. The factum of lending the money through banking channels is not doubted by the Revenue. Further the identity and capacity of the lender is proved by the fact that the assessee has placed documents to show that lender is an Income Tax payer, is assessed to tax and for the year under consideration, the lender has disclosed gross total income which is more than the amount advanced. - Additions deleted - AT
Addition u/s. 68 - on the amounts received as loan, assessee had paid interest and had also deducted TDS on the interest paid. The factum of lending the money through banking channels is not doubted by the Revenue. Further the identity and capacity of the lender is proved by the fact that the assessee has placed documents to show that lender is an Income Tax payer, is assessed to tax and for the year under consideration, the lender has disclosed gross total income which is more than the amount advanced. - Additions deleted - AT
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