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 modified multiple additions in a tax appeal concerning bogus purchases and unexplained money. For contested purchases of Rs. 13,80,63,994, ITAT directed application of 5% profit rate, restricting addition to Rs. 69,03,200, consistent with preceding assessment years. Regarding unexplained money evidenced in seized documents from Director's premises, addition was deleted as Director claimed personal ownership in statement u/s 132(4). For unaccounted flat transactions of Rs. 17,42,000, ITAT applied 5% profit rate, resulting in addition of Rs. 87,100. On disputed entries marked as "6kg" and "7kg", ITAT modified addition to Rs. 1,30,000 total, considering subsequent retraction and lack of corroborative evidence. Revenue's appeals were partly allowed across all issues.
ITAT modified multiple additions in a tax appeal concerning bogus purchases and unexplained money. For contested purchases of Rs. 13,80,63,994, ITAT directed application of 5% profit rate, restricting addition to Rs. 69,03,200, consistent with preceding assessment years. Regarding unexplained money evidenced in seized documents from Director's premises, addition was deleted as Director claimed personal ownership in statement u/s 132(4). For unaccounted flat transactions of Rs. 17,42,000, ITAT applied 5% profit rate, resulting in addition of Rs. 87,100. On disputed entries marked as "6kg" and "7kg", ITAT modified addition to Rs. 1,30,000 total, considering subsequent retraction and lack of corroborative evidence. Revenue's appeals were partly allowed across all issues.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
