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...
Validity of proceedings u/s 153C - The Tribunal upheld the proceedings u/s 153C, agreeing with the CIT(A)'s decision that the material seized during the search had a bearing on the determination of the assessee's total income, thereby justifying the assumption of jurisdiction u/s 153C. - The Tribunal concurred with the CIT(A) that the seized documents and the statements, especially when retracted, could not be solely relied upon to make additions to the assessee's income. It was emphasized that corroborative evidence was necessary to attribute the entries in the seized materials to the assessee. - The Tribunal agreed with the CIT(A)'s deletion of these additions, finding no direct reference to the assessee in the seized materials and considering the statements unreliable without independent corroborative evidence.
Validity of proceedings u/s 153C - The Tribunal upheld the proceedings u/s 153C, agreeing with the CIT(A)'s decision that the material seized during the search had a bearing on the determination of the assessee's total income, thereby justifying the assumption of jurisdiction u/s 153C. - The Tribunal concurred with the CIT(A) that the seized documents and the statements, especially when retracted, could not be solely relied upon to make additions to the assessee's income. It was emphasized that corroborative evidence was necessary to attribute the entries in the seized materials to the assessee. - The Tribunal agreed with the CIT(A)'s deletion of these additions, finding no direct reference to the assessee in the seized materials and considering the statements unreliable without independent corroborative evidence.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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