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...
Assessment u/s 153A lacked incriminating material - additions arbitrary. Fictitious commodity losses disallowed due to absence of tangible evidence of undisclosed income or unaccounted assets. Reassessment requires incriminating material as per Saumya Construction case. Unexplained credits u/s 68 deleted as AO failed to verify "source of source" despite assessee providing information. Disallowance u/s 14A r.w.r.8D deleted for unabated years lacking incriminating material, following Saumya Construction and Kabul Chawla cases. Assessee being share dealer doesn't exempt from Section 14A. Revenue's grounds dismissed, assessee's allowed.
Assessment u/s 153A lacked incriminating material - additions arbitrary. Fictitious commodity losses disallowed due to absence of tangible evidence of undisclosed income or unaccounted assets. Reassessment requires incriminating material as per Saumya Construction case. Unexplained credits u/s 68 deleted as AO failed to verify "source of source" despite assessee providing information. Disallowance u/s 14A r.w.r.8D deleted for unabated years lacking incriminating material, following Saumya Construction and Kabul Chawla cases. Assessee being share dealer doesn't exempt from Section 14A. Revenue's grounds dismissed, assessee's allowed.
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