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 reopening of assessment u/s 147 - Reason to believe - Addition u/s 69C on account of the capital introduced by the partner and unsecured loans - The Tribunal upheld the validity of the reassessment proceedings, citing the absence of a request for reasons during the assessment or appellate proceedings. However, it ruled in favor of the Assessee regarding the additions under section 69C. The Tribunal emphasized the Assessee's compliance with providing evidence and shifted the onus to the AO to justify rejecting the explanations provided.
Validity of reopening of assessment u/s 147 - Reason to believe - Addition u/s 69C on account of the capital introduced by the partner and unsecured loans - The Tribunal upheld the validity of the reassessment proceedings, citing the absence of a request for reasons during the assessment or appellate proceedings. However, it ruled in favor of the Assessee regarding the additions under section 69C. The Tribunal emphasized the Assessee's compliance with providing evidence and shifted the onus to the AO to justify rejecting the explanations provided.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
