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...
Assessment u/s 153A - Addition of undisclosed income - Contract between assessee and non-resident entity for sharing profits from supply of currency paper to RBI - No incriminating material found during search and seizure - Agreement terminated in 2012 and assessee became non-resident from 2015-16 onwards - Receipts from foreign entities pertain to later years - Revenue unable to establish link between payments and terminated agreement - ITAT rightly deleted additions based on lack of incriminating evidence - No substantial questions of law arise.
Assessment u/s 153A - Addition of undisclosed income - Contract between assessee and non-resident entity for sharing profits from supply of currency paper to RBI - No incriminating material found during search and seizure - Agreement terminated in 2012 and assessee became non-resident from 2015-16 onwards - Receipts from foreign entities pertain to later years - Revenue unable to establish link between payments and terminated agreement - ITAT rightly deleted additions based on lack of incriminating evidence - No substantial questions of law arise.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
