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 u/s 69B r.w.s.115BBE - during the course of survey action discrepancies were found on account of physical verification of stock vis-a-vis regular books of account - The AO and CIT(A) classified this as unexplained investment, leading to a higher tax rate. However, the Tribunal, after considering the facts and various precedents, concluded that the excess stock was indeed related to the regular business operations and not an unexplained investment. Therefore, it directed the AO to assess the surrendered income as business income and apply the normal tax rate, ultimately allowing the assessee's appeal.
Addition u/s 69B r.w.s.115BBE - during the course of survey action discrepancies were found on account of physical verification of stock vis-a-vis regular books of account - The AO and CIT(A) classified this as unexplained investment, leading to a higher tax rate. However, the Tribunal, after considering the facts and various precedents, concluded that the excess stock was indeed related to the regular business operations and not an unexplained investment. Therefore, it directed the AO to assess the surrendered income as business income and apply the normal tax rate, ultimately allowing the assessee's appeal.
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TaxTMI 
TaxTMI 
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