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...
Disallowances on account of non-payment of VAT before prescribed return filing date u/s 139(1) - assessee's submission of exclusive method of accounting without debiting VAT to profit and loss account rejected. Reliance on Ganapati Motors case distinguished as authorities had doubted and rejected assessee's accounting system, unlike in cited case. CIT(A) rightly discarded assessee's exclusive accounting method contrary to section 145A(ii) and Bombay High Court's decision in CIT vs. Knight Frank. Arguments incomprehensible due to factual differences from Ganapati Motors. No infirmity in CIT(A)'s confirmation of disallowance u/s 143(1). Partial deletion by CIT(A) of disallowance pertaining to earlier year upheld as settled law prohibits addition/disallowance of expenditure of different year in relevant year.
Disallowances on account of non-payment of VAT before prescribed return filing date u/s 139(1) - assessee's submission of exclusive method of accounting without debiting VAT to profit and loss account rejected. Reliance on Ganapati Motors case distinguished as authorities had doubted and rejected assessee's accounting system, unlike in cited case. CIT(A) rightly discarded assessee's exclusive accounting method contrary to section 145A(ii) and Bombay High Court's decision in CIT vs. Knight Frank. Arguments incomprehensible due to factual differences from Ganapati Motors. No infirmity in CIT(A)'s confirmation of disallowance u/s 143(1). Partial deletion by CIT(A) of disallowance pertaining to earlier year upheld as settled law prohibits addition/disallowance of expenditure of different year in relevant year.
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TaxTMI 
TaxTMI 
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