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 examined unverifiable purchases from 22 parties where assessee failed to provide conclusive proof. While books of accounts were accepted by AO and historical gross profit rates averaged 1.55% with current year at 1.6%, the Tribunal determined these transactions likely occurred in grey market warranting higher margins. Despite prior assessments under s.143(3) raising no concerns, ITAT estimated a 2.5% profit margin on disputed purchase value as reasonable given the informal nature of transactions. This modified profit estimation approach balanced the established business pattern with appropriate adjustments for unverified grey market dealings. Appeal partially allowed with revised profit computation.
ITAT examined unverifiable purchases from 22 parties where assessee failed to provide conclusive proof. While books of accounts were accepted by AO and historical gross profit rates averaged 1.55% with current year at 1.6%, the Tribunal determined these transactions likely occurred in grey market warranting higher margins. Despite prior assessments under s.143(3) raising no concerns, ITAT estimated a 2.5% profit margin on disputed purchase value as reasonable given the informal nature of transactions. This modified profit estimation approach balanced the established business pattern with appropriate adjustments for unverified grey market dealings. Appeal partially allowed with revised profit computation.
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TaxTMI 
TaxTMI 
of 4921 
