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...
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The case deals with addition u/s 68 for unexplained cash credit from alleged bogus unsecured loans. The Assessing Officer (AO) added the peak credit without establishing genuineness or creditworthiness. However, the assessee provided substantial evidence of identity, genuineness, and creditworthiness of the loan creditors, including confirmations, ID proofs, bank statements, and tax returns. Repayment in subsequent years supported transaction genuineness. The AO's conclusions relied on assumptions without contradicting evidence. Citing legal precedent, the CIT(A) rightly noted lack of adverse comments in the remand report. The ITAT upheld the CIT(A)'s decision, dismissing the Revenue's appeal.
The case deals with addition u/s 68 for unexplained cash credit from alleged bogus unsecured loans. The Assessing Officer (AO) added the peak credit without establishing genuineness or creditworthiness. However, the assessee provided substantial evidence of identity, genuineness, and creditworthiness of the loan creditors, including confirmations, ID proofs, bank statements, and tax returns. Repayment in subsequent years supported transaction genuineness. The AO's conclusions relied on assumptions without contradicting evidence. Citing legal precedent, the CIT(A) rightly noted lack of adverse comments in the remand report. The ITAT upheld the CIT(A)'s decision, dismissing the Revenue's appeal.
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