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...
Bogus share transactions involving abnormal price rise in penny stock shares - Assessee produced evidence of share purchase, existence in demat account - AO failed to rebut assessee's evidence, merely relied on circumstantial evidence - Ignorance of assessee about company's financials not crucial when transactions substantiated - Denial of exemption u/s 10(38) not justified - Addition u/s 68 deleted by CIT(A), upheld by ITAT - AO should have discharged onus after assessee's evidence.
Bogus share transactions involving abnormal price rise in penny stock shares - Assessee produced evidence of share purchase, existence in demat account - AO failed to rebut assessee's evidence, merely relied on circumstantial evidence - Ignorance of assessee about company's financials not crucial when transactions substantiated - Denial of exemption u/s 10(38) not justified - Addition u/s 68 deleted by CIT(A), upheld by ITAT - AO should have discharged onus after assessee's evidence.
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