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...
ITAT ruled against addition under s.68 regarding unexplained cash credits from company directors. Directors made payments to 169 individuals for property acquisition on company's behalf, rather than direct loans to company. Documentation included payment confirmations and proper balance sheet entries showing director liabilities. Tribunal held that assessee discharged burden of proof by demonstrating genuine nature of transactions through third-party confirmations and establishing clear money trail for property purchases. The fact that directors obtained unsecured loans to make these payments did not justify addition under s.68 when supported by comprehensive documentation. Addition made by AO and upheld by CIT(A) was deleted.
ITAT ruled against addition under s.68 regarding unexplained cash credits from company directors. Directors made payments to 169 individuals for property acquisition on company's behalf, rather than direct loans to company. Documentation included payment confirmations and proper balance sheet entries showing director liabilities. Tribunal held that assessee discharged burden of proof by demonstrating genuine nature of transactions through third-party confirmations and establishing clear money trail for property purchases. The fact that directors obtained unsecured loans to make these payments did not justify addition under s.68 when supported by comprehensive documentation. Addition made by AO and upheld by CIT(A) was deleted.
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