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...
The AO failed to correctly compute the undisclosed income after considering the correct sale value of land as per Form 26AS. The assessee claimed that one of the lands in Form 26AS pertained to "Vaibhav Corporation Pvt. Ltd." and not to him, requiring further verification by the AO. However, the AO failed to make the correct addition u/s 68 and failed to consider the cash deposit, resulting in underassessment of income. The PCIT invoked revision proceedings u/s 263, despite the assessee providing evidence that the sale of property was done by "Vaibhav Corporation Pvt. Ltd." and not by the assessee, including the relevant Form 26AS and a letter from the Sub-Registrar confirming the same. The ITAT held that when such evidence was filed, the PCIT should have dropped the revision proceedings, as incorrect calculation of income is rectifiable u/s 154 and not by invoking Section 263. The ITAT quashed the PCIT's revision order and allowed the assessee's appeal.
The AO failed to correctly compute the undisclosed income after considering the correct sale value of land as per Form 26AS. The assessee claimed that one of the lands in Form 26AS pertained to "Vaibhav Corporation Pvt. Ltd." and not to him, requiring further verification by the AO. However, the AO failed to make the correct addition u/s 68 and failed to consider the cash deposit, resulting in underassessment of income. The PCIT invoked revision proceedings u/s 263, despite the assessee providing evidence that the sale of property was done by "Vaibhav Corporation Pvt. Ltd." and not by the assessee, including the relevant Form 26AS and a letter from the Sub-Registrar confirming the same. The ITAT held that when such evidence was filed, the PCIT should have dropped the revision proceedings, as incorrect calculation of income is rectifiable u/s 154 and not by invoking Section 263. The ITAT quashed the PCIT's revision order and allowed the assessee's appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
