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...
Addition u/s 68/69A/69B and taxed the same u/s 115BBE - Surrendered income in survey - The Tribunal found that the income was directly linked to the assessee's regular business operations, negating the Revenue's claim of it being unexplained investment. The ITAT rectified the issue of double taxation by instructing the Assessing Officer to reassess the income appropriately and allowed the depreciation claim on the building costs, recognizing that the assessee had already paid taxes on the entire surrendered amount.
Addition u/s 68/69A/69B and taxed the same u/s 115BBE - Surrendered income in survey - The Tribunal found that the income was directly linked to the assessee's regular business operations, negating the Revenue's claim of it being unexplained investment. The ITAT rectified the issue of double taxation by instructing the Assessing Officer to reassess the income appropriately and allowed the depreciation claim on the building costs, recognizing that the assessee had already paid taxes on the entire surrendered amount.
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