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...
Additions against Over-invoicing of Purchases - The Tribunal found that the AO's selective reliance on pieces of evidence without considering the entirety of the material was unjustified. Consequently, the Tribunal upheld the CIT(A)'s decision to delete the additions related to over-invoicing. - Regarding the undervaluation of stock, the Tribunal observed that the documents presumed to demonstrate unexplained investment were prepared for strategic purposes, showcasing notional values for presentation to potential investors. It was determined that these notional figures could not form the basis for additions under section 69B.
Additions against Over-invoicing of Purchases - The Tribunal found that the AO's selective reliance on pieces of evidence without considering the entirety of the material was unjustified. Consequently, the Tribunal upheld the CIT(A)'s decision to delete the additions related to over-invoicing. - Regarding the undervaluation of stock, the Tribunal observed that the documents presumed to demonstrate unexplained investment were prepared for strategic purposes, showcasing notional values for presentation to potential investors. It was determined that these notional figures could not form the basis for additions under section 69B.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
