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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Assessment u/s 153A was quashed due to improper approval granted u/s 153D by JCIT through a common mechanical communication without application of mind. Addition u/s 10(38) was deleted as opportunity for cross-examination of witness whose statement was relied upon was not provided, violating principles of natural justice as per Supreme Court's decision in Andaman Timber Industries case. Commission addition at 0.2% was also deleted. Disallowance of business promotion expenses for non-production of bills/vouchers was deleted following Delhi High Court's decision in R.G. Buildwell Engineers Ltd. case, approved by Supreme Court, holding that disallowance cannot be made without rejecting books of account.
Assessment u/s 153A was quashed due to improper approval granted u/s 153D by JCIT through a common mechanical communication without application of mind. Addition u/s 10(38) was deleted as opportunity for cross-examination of witness whose statement was relied upon was not provided, violating principles of natural justice as per Supreme Court's decision in Andaman Timber Industries case. Commission addition at 0.2% was also deleted. Disallowance of business promotion expenses for non-production of bills/vouchers was deleted following Delhi High Court's decision in R.G. Buildwell Engineers Ltd. case, approved by Supreme Court, holding that disallowance cannot be made without rejecting books of account.
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