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 case pertains to the estimation of income and disallowance of bogus purchases. The purchases were deemed sham transactions fabricated through bogus paper concerns engaged in providing accommodation entries. The Income Tax Appellate Tribunal (ITAT) partly allowed the Revenue's appeal, holding that for bogus purchases, the addition at the rate of 6% of the bogus purchases was fair and reasonable. The High Court upheld the ITAT's view, stating that the conclusion was based on the material and analysis of facts and figures available. The court found no substantial questions of law arising from the ITAT's decision to reduce the disallowance from 12.5% to 6% for the bogus purchases.
The case pertains to the estimation of income and disallowance of bogus purchases. The purchases were deemed sham transactions fabricated through bogus paper concerns engaged in providing accommodation entries. The Income Tax Appellate Tribunal (ITAT) partly allowed the Revenue's appeal, holding that for bogus purchases, the addition at the rate of 6% of the bogus purchases was fair and reasonable. The High Court upheld the ITAT's view, stating that the conclusion was based on the material and analysis of facts and figures available. The court found no substantial questions of law arising from the ITAT's decision to reduce the disallowance from 12.5% to 6% for the bogus purchases.
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