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...
Accrual of income - Addition made to the income of the assessee received by the assessee from “JDS” and its associates, treated as own income of the assessee - Despite the Department's awareness of the true nature of the transactions, the addition was confirmed by the lower authorities based on certain factors, including the deletion of similar additions in the case of the ultimate beneficiary and the appellant's previous assessment. However, the Appellate Tribunal, relying on legal precedents and the evidence presented, concluded that the funds received by the appellant were not their own income but were meant for the ultimate beneficiary. - Additions deleted.
Accrual of income - Addition made to the income of the assessee received by the assessee from “JDS” and its associates, treated as own income of the assessee - Despite the Department's awareness of the true nature of the transactions, the addition was confirmed by the lower authorities based on certain factors, including the deletion of similar additions in the case of the ultimate beneficiary and the appellant's previous assessment. However, the Appellate Tribunal, relying on legal precedents and the evidence presented, concluded that the funds received by the appellant were not their own income but were meant for the ultimate beneficiary. - Additions deleted.
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