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...
The Appellate Tribunal held that the case was selected for "limited scrutiny" based on large cash deposits and property transfers. The addition u/s 56(2)(vii)(b) for the difference between Fair Market Value and actual consideration was not justified. The addition did not relate to the basis for limited scrutiny. The Tribunal cited M/s. Suraj Diamond Dealers Pvt. Ltd., stating that the AO can only go beyond limited scrutiny reasons with approval. The AO's addition was deemed erroneous as it was not part of the limited scrutiny reasons, thus the appeal grounds were allowed.
The Appellate Tribunal held that the case was selected for "limited scrutiny" based on large cash deposits and property transfers. The addition u/s 56(2)(vii)(b) for the difference between Fair Market Value and actual consideration was not justified. The addition did not relate to the basis for limited scrutiny. The Tribunal cited M/s. Suraj Diamond Dealers Pvt. Ltd., stating that the AO can only go beyond limited scrutiny reasons with approval. The AO's addition was deemed erroneous as it was not part of the limited scrutiny reasons, thus the appeal grounds were allowed.
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