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...
Cash deposit during demonetization period treated as unexplained cash credit. Assessee's claim of introducing cash as capital in proprietary concern not accepted due to lack of evidence regarding availability of substantial cash. AO's view upheld that assessee's cash withdrawals from bank accounts indicate absence of substantial personal cash holdings. Assessee's cash in hand on date of deposit reduced by alleged capital introduction amount. Remaining cash in hand treated as source for deposit, with balance addition treated as unexplained cash credit. Appeal partly allowed.
Cash deposit during demonetization period treated as unexplained cash credit. Assessee's claim of introducing cash as capital in proprietary concern not accepted due to lack of evidence regarding availability of substantial cash. AO's view upheld that assessee's cash withdrawals from bank accounts indicate absence of substantial personal cash holdings. Assessee's cash in hand on date of deposit reduced by alleged capital introduction amount. Remaining cash in hand treated as source for deposit, with balance addition treated as unexplained cash credit. Appeal partly allowed.
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