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 153A was made for deemed dividend u/s 2(22)(e). However, following Abhisar Buildwell P. Ltd. [2023 (4) TMI 1056 - Supreme Court], the High Court held that the Assessing Officer would not be justified to assess income in the absence of incriminating material found during the search. As no such incriminating material was placed before the Court, the substantial questions of law were answered against the Revenue, affirming the Appellate Tribunal's order.
Addition u/s 153A was made for deemed dividend u/s 2(22)(e). However, following Abhisar Buildwell P. Ltd. [2023 (4) TMI 1056 - Supreme Court], the High Court held that the Assessing Officer would not be justified to assess income in the absence of incriminating material found during the search. As no such incriminating material was placed before the Court, the substantial questions of law were answered against the Revenue, affirming the Appellate Tribunal's order.
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TaxTMI 
TaxTMI 
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