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...
Unexplained Cash Credit u/s 68 - Authenticity of the Will - sale consideration claimed to have been received by the appellant from sale of gold ornament and diamonds, which were given to him by his late grandmother by way of a will - The Tribunal noted the discrepancies in the age of the testator and absence of probate were crucial in questioning the authenticity of the Will. The appellant failed to provide independent evidence to corroborate the existence and possession of the assets at the time the Will was made. The Tribunal found it improbable that a housewife without a visible source of income could possess such high-value assets. Consequently, the appeal of the assessee was dismissed.
Unexplained Cash Credit u/s 68 - Authenticity of the Will - sale consideration claimed to have been received by the appellant from sale of gold ornament and diamonds, which were given to him by his late grandmother by way of a will - The Tribunal noted the discrepancies in the age of the testator and absence of probate were crucial in questioning the authenticity of the Will. The appellant failed to provide independent evidence to corroborate the existence and possession of the assets at the time the Will was made. The Tribunal found it improbable that a housewife without a visible source of income could possess such high-value assets. Consequently, the appeal of the assessee was dismissed.
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