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...
The ITAT set aside CIT(A)'s order regarding unexplained investments under s.69 and additions under s.69A during the demonetization period. The case involved disputed bank deposits in Party A's account and statements recorded under s.131(1A). While the AO made additions based on partner statements and survey reports, they failed to follow mandatory CBDT SOPs and guidelines for demonetization cases. The Tribunal directed the AO to conduct fresh assessment following prescribed verification procedures, examine all evidence, and consider the assessee's claims in accordance with law. The ruling emphasized binding nature of CBDT circulars on tax officers and the necessity for uniform approach in handling demonetization-related assessments. Matter remanded for fresh consideration.
The ITAT set aside CIT(A)'s order regarding unexplained investments under s.69 and additions under s.69A during the demonetization period. The case involved disputed bank deposits in Party A's account and statements recorded under s.131(1A). While the AO made additions based on partner statements and survey reports, they failed to follow mandatory CBDT SOPs and guidelines for demonetization cases. The Tribunal directed the AO to conduct fresh assessment following prescribed verification procedures, examine all evidence, and consider the assessee's claims in accordance with law. The ruling emphasized binding nature of CBDT circulars on tax officers and the necessity for uniform approach in handling demonetization-related assessments. Matter remanded for fresh consideration.
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TaxTMI 
TaxTMI 
of 4918 
