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 of bogus sales - difference in opinion between learned Members constituting the bench - The appellate tribunal (Third Member) addressed the dispute arising from alleged bogus sales transactions during the demonetization period. The Assessing Officer treated these transactions as unexplained cash credit under Section 68 of the Income Tax Act. However, the Tribunal found that the assessee sufficiently proved the authenticity of the sales through meticulous record-keeping and documentary evidence, despite challenges such as non-responses from some parties and allegations of sham transactions. - The Third Member upheld the decision of the learned Accountant Member to reject the addition under Section 68, considering the adequacy of evidence presented by the assessee.
Addition of bogus sales - difference in opinion between learned Members constituting the bench - The appellate tribunal (Third Member) addressed the dispute arising from alleged bogus sales transactions during the demonetization period. The Assessing Officer treated these transactions as unexplained cash credit under Section 68 of the Income Tax Act. However, the Tribunal found that the assessee sufficiently proved the authenticity of the sales through meticulous record-keeping and documentary evidence, despite challenges such as non-responses from some parties and allegations of sham transactions. - The Third Member upheld the decision of the learned Accountant Member to reject the addition under Section 68, considering the adequacy of evidence presented by the assessee.
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TaxTMI 
TaxTMI 
of 4918 
