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...
Additions based on Cash Expenditure - Disclosure were made by the appellant in IDS - The Tribunal ruled in favor of the appellant, holding that the entries did not warrant additional taxation. It noted that the expenses were from known sources and reconciled with existing books, thus not constituting unexplained expenditure under section 69C. Moreover, it accepted the appellant's claim regarding the disclosure under the Income Declaration Scheme, 2016, ruling that the expenses should not be treated as taxable income.
Additions based on Cash Expenditure - Disclosure were made by the appellant in IDS - The Tribunal ruled in favor of the appellant, holding that the entries did not warrant additional taxation. It noted that the expenses were from known sources and reconciled with existing books, thus not constituting unexplained expenditure under section 69C. Moreover, it accepted the appellant's claim regarding the disclosure under the Income Declaration Scheme, 2016, ruling that the expenses should not be treated as taxable income.
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