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 Referring the matter to DVO - Additions based on valuation report - The High Court noted that the assessee had filed its return for the relevant assessment year supported by audited books of accounts. The AO, without rejecting these books, referred the matter to the DVO. The High Court observed that the books of accounts were not rejected before a certain date, and the rejection occurred later based on the DVO's report. Citing precedent, the High Court emphasized that the AO could not refer the matter to the DVO without first rejecting the books of account. - The High Court upheld the ITAT's decision to delete the addition made by the AO based on the valuation report. It reiterated that the reference to the DVO was not lawful, and therefore, the estimation made by the DVO could not be relied upon for making the assessment.
Validity of Referring the matter to DVO - Additions based on valuation report - The High Court noted that the assessee had filed its return for the relevant assessment year supported by audited books of accounts. The AO, without rejecting these books, referred the matter to the DVO. The High Court observed that the books of accounts were not rejected before a certain date, and the rejection occurred later based on the DVO's report. Citing precedent, the High Court emphasized that the AO could not refer the matter to the DVO without first rejecting the books of account. - The High Court upheld the ITAT's decision to delete the addition made by the AO based on the valuation report. It reiterated that the reference to the DVO was not lawful, and therefore, the estimation made by the DVO could not be relied upon for making the assessment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
