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 ITAT held that the addition of Rs. 2.5 crore to the assessee's income was unsustainable. It was not established that the assessee actually received the said amount. The entire sales were duly recorded, and no evidence proved receipt of the impugned sum. The addition was made without any charging provision under the law. The ITAT ruled in favor of the assessee, setting aside the orders of the AO and CIT(A).
The ITAT held that the addition of Rs. 2.5 crore to the assessee's income was unsustainable. It was not established that the assessee actually received the said amount. The entire sales were duly recorded, and no evidence proved receipt of the impugned sum. The addition was made without any charging provision under the law. The ITAT ruled in favor of the assessee, setting aside the orders of the AO and CIT(A).
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