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...
Levy of penalty u/s 271AAB - assessee has inflated his agricultural income, which would have been otherwise offered under any other head of income - any disclosures made in the course of search and statement recorded u/s.132(4) itself cannot be construed as “undisclosed income” as per the definition provided in the Act. There is no incriminating material found by the Revenue on the alleged additional income offered by the assessee. - AT
Levy of penalty u/s 271AAB - assessee has inflated his agricultural income, which would have been otherwise offered under any other head of income - any disclosures made in the course of search and statement recorded u/s.132(4) itself cannot be construed as “undisclosed income” as per the definition provided in the Act. There is no incriminating material found by the Revenue on the alleged additional income offered by the assessee. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
