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 u/s 69A - Addition of cash deposits made by the assessee during the demonetization period - The Tribunal examined the legality of the assessment order, the justification for the cash deposits, and the imposition of interest and penalty. It found the assessment order to be valid but disagreed with the A.O's reasoning for the cash deposit addition. The Tribunal partially allowed the appeal, reducing the addition amount based on the assessee's available cash and savings. It upheld the charging of interest but deemed the initiation of penalty proceedings premature.
Addition u/s 69A - Addition of cash deposits made by the assessee during the demonetization period - The Tribunal examined the legality of the assessment order, the justification for the cash deposits, and the imposition of interest and penalty. It found the assessment order to be valid but disagreed with the A.O's reasoning for the cash deposit addition. The Tribunal partially allowed the appeal, reducing the addition amount based on the assessee's available cash and savings. It upheld the charging of interest but deemed the initiation of penalty proceedings premature.
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