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...
Undisclosed cash credit u/s 68 - non-appearance of directors - As per DR assessee has failed to prove the genuineness of transaction and creditworthiness of the share applicants - The Ld. CIT(A) found that the AO did not properly consider the documentary evidence provided by the assessee, including the identities and creditworthiness of the share applicants and the genuineness of the transactions. - Accordingly, the ITAT confirmed the order of CIT(A) deleting the additions.
Undisclosed cash credit u/s 68 - non-appearance of directors - As per DR assessee has failed to prove the genuineness of transaction and creditworthiness of the share applicants - The Ld. CIT(A) found that the AO did not properly consider the documentary evidence provided by the assessee, including the identities and creditworthiness of the share applicants and the genuineness of the transactions. - Accordingly, the ITAT confirmed the order of CIT(A) deleting the additions.
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