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...
Unexplained money u/s 69A r.w.s. 115BBE - Cash seized in search - The assessee provided a cash reconciliation statement, demonstrating that the cash balance remained consistent after the inter-branch transfer. The statement showed that the cash was transferred from the Kolkata branch to the Gurgaon branch, with corresponding entries in the cash books of both branches. Additionally, the cash transferred was recorded in the books with a slight delay, but the company as a whole maintained sufficient cash balance to explain the seized amount. - ITAT deleted the additions.
Unexplained money u/s 69A r.w.s. 115BBE - Cash seized in search - The assessee provided a cash reconciliation statement, demonstrating that the cash balance remained consistent after the inter-branch transfer. The statement showed that the cash was transferred from the Kolkata branch to the Gurgaon branch, with corresponding entries in the cash books of both branches. Additionally, the cash transferred was recorded in the books with a slight delay, but the company as a whole maintained sufficient cash balance to explain the seized amount. - ITAT deleted the additions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
