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...
Assessee showed higher wastage of 13.04% on consumption of worsted yarn compared to 8.66% in previous year. AO made addition for excessive shortage and scrap value of discarded cables. Held: Trading account and stock found satisfactory by tax authorities. Wastage percentage varied from 13.64% to 16.43% in earlier years, decreased to 8.66% for 3 months in 1982-83, but remained consistent at 13.04% in 1983-84. No objection raised by Excise Authorities on stock maintained. AO accepted trading account, no dispute on quantity of cotton consumed. AO cannot make addition without reasoning and fresh computation when accounts accepted u/s 145(1). Addition on account of excessive shortage not sustainable. Addition of profit u/s 41(2) on sale of copper wire: AO made addition based on assumptions and presumptions despite assessee's explanations and no evidence of tax evasion found during factory visit. HC held Tribunal erred in assessing additions made by AO. Reference answered in favor of assessee against revenue.
Assessee showed higher wastage of 13.04% on consumption of worsted yarn compared to 8.66% in previous year. AO made addition for excessive shortage and scrap value of discarded cables. Held: Trading account and stock found satisfactory by tax authorities. Wastage percentage varied from 13.64% to 16.43% in earlier years, decreased to 8.66% for 3 months in 1982-83, but remained consistent at 13.04% in 1983-84. No objection raised by Excise Authorities on stock maintained. AO accepted trading account, no dispute on quantity of cotton consumed. AO cannot make addition without reasoning and fresh computation when accounts accepted u/s 145(1). Addition on account of excessive shortage not sustainable. Addition of profit u/s 41(2) on sale of copper wire: AO made addition based on assumptions and presumptions despite assessee's explanations and no evidence of tax evasion found during factory visit. HC held Tribunal erred in assessing additions made by AO. Reference answered in favor of assessee against revenue.
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