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...
ITAT reversed additions made under sections 41(1) and 69 of Income Tax Act. Regarding s.41(1), outstanding trade payables to supplier since FY 2011-12 for defective materials were consistently shown in books, with no cessation of liability established. Following precedent, mere non-payment without remission does not satisfy s.41(1) requirements. Previous ITAT ruling for AY 2012-13 had already examined creditor authenticity. On s.69 addition, demand draft for land registration was properly recorded as fixed asset in FY 2014-15 books, negating unexplained investment presumption. Revenue's contradictory position in subsequent year deemed improper. Appeal allowed with both additions deleted.
ITAT reversed additions made under sections 41(1) and 69 of Income Tax Act. Regarding s.41(1), outstanding trade payables to supplier since FY 2011-12 for defective materials were consistently shown in books, with no cessation of liability established. Following precedent, mere non-payment without remission does not satisfy s.41(1) requirements. Previous ITAT ruling for AY 2012-13 had already examined creditor authenticity. On s.69 addition, demand draft for land registration was properly recorded as fixed asset in FY 2014-15 books, negating unexplained investment presumption. Revenue's contradictory position in subsequent year deemed improper. Appeal allowed with both additions deleted.
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