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 reversed AO's addition under section 68 regarding alleged bogus long-term capital gains (LTCG). The tribunal found insufficient evidence to reject taxpayer's claim for exemption under section 10(38), as documentary evidence supported genuine share transactions. AO's rejection was based solely on unsubstantiated statements from individuals who were not produced for cross-examination. The related addition of estimated 2% commission was also deleted, as the underlying LTCG transactions were held genuine. CIT(A)'s deletion of additions was upheld, and Revenue's appeal was dismissed due to lack of merit in challenging the authenticity of share transactions.
ITAT reversed AO's addition under section 68 regarding alleged bogus long-term capital gains (LTCG). The tribunal found insufficient evidence to reject taxpayer's claim for exemption under section 10(38), as documentary evidence supported genuine share transactions. AO's rejection was based solely on unsubstantiated statements from individuals who were not produced for cross-examination. The related addition of estimated 2% commission was also deleted, as the underlying LTCG transactions were held genuine. CIT(A)'s deletion of additions was upheld, and Revenue's appeal was dismissed due to lack of merit in challenging the authenticity of share transactions.
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