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 68 deleted - sum received towards share premium not treated as undisclosed income - assessee considered an entry operator, not engaged in actual business, earning commission income. Percentage of commission income estimated at 0.75% by CIT(A) considered high, reduced to 0.5% based on assessee's concession, applied on total share capital and premium of Rs. 40 crore. Assessee's cross-objection partly allowed.
Addition u/s 68 deleted - sum received towards share premium not treated as undisclosed income - assessee considered an entry operator, not engaged in actual business, earning commission income. Percentage of commission income estimated at 0.75% by CIT(A) considered high, reduced to 0.5% based on assessee's concession, applied on total share capital and premium of Rs. 40 crore. Assessee's cross-objection partly allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
