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 based on voluntary disclosure made by the key person of the assesse group during the course of search which has subsequently been retracted - The statement recorded u/s 132(4) - The Tribunal observed that admissions made under duress or misconception can be retracted. The reliance solely on such statements for making additions, without corroborative evidence, is not sustainable. - The Tribunal held that without any incriminating material specifically linking the income to undisclosed sources, the disclosed income should be treated as business income, not taxable u/s 115BBE.
Addition based on voluntary disclosure made by the key person of the assesse group during the course of search which has subsequently been retracted - The statement recorded u/s 132(4) - The Tribunal observed that admissions made under duress or misconception can be retracted. The reliance solely on such statements for making additions, without corroborative evidence, is not sustainable. - The Tribunal held that without any incriminating material specifically linking the income to undisclosed sources, the disclosed income should be treated as business income, not taxable u/s 115BBE.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
