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 dismissed Revenue's appeal on multiple grounds. AO's adoption of Rs. 3,000/sq.ft. as commercial space sale price was rejected due to lack of concrete evidence beyond mere statements. The tribunal upheld CIT(A)'s decision on reimbursement of expenditure, following precedent that Revenue cannot take contrary positions among group assessees. Addition for out-of-court settlement amount was deleted as it would result in double taxation since Rs. 83 lakhs was already declared as income. Regarding expenditure on commercial space sale, CIT(A)'s deletion of addition was sustained as expenses were properly documented through banking channels. Revenue's objection about remand report was dismissed as available evidence was sufficient for determination.
ITAT dismissed Revenue's appeal on multiple grounds. AO's adoption of Rs. 3,000/sq.ft. as commercial space sale price was rejected due to lack of concrete evidence beyond mere statements. The tribunal upheld CIT(A)'s decision on reimbursement of expenditure, following precedent that Revenue cannot take contrary positions among group assessees. Addition for out-of-court settlement amount was deleted as it would result in double taxation since Rs. 83 lakhs was already declared as income. Regarding expenditure on commercial space sale, CIT(A)'s deletion of addition was sustained as expenses were properly documented through banking channels. Revenue's objection about remand report was dismissed as available evidence was sufficient for determination.
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TaxTMI 
TaxTMI 
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