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 held revisionary powers under s.263 cannot be invoked as assessment order was neither erroneous nor prejudicial to Revenue's interests. During survey, assessee surrendered undisclosed income which was included in tax returns. AO conducted specific inquiry regarding applicability of s.115BBE through show cause notice. PCIT cannot merely substitute their view that income should be treated as unexplained investment under s.69 (Rs.66,50,000) and unexplained money under s.69A (Rs.9,50,000). Amendment via Explanation 2(a) expanding revisionary powers does not grant unlimited authority. No errors of law or fact were found in AO's order, which represented a plausible interpretation after proper inquiry. Appeal decided in assessee's favor.
ITAT held revisionary powers under s.263 cannot be invoked as assessment order was neither erroneous nor prejudicial to Revenue's interests. During survey, assessee surrendered undisclosed income which was included in tax returns. AO conducted specific inquiry regarding applicability of s.115BBE through show cause notice. PCIT cannot merely substitute their view that income should be treated as unexplained investment under s.69 (Rs.66,50,000) and unexplained money under s.69A (Rs.9,50,000). Amendment via Explanation 2(a) expanding revisionary powers does not grant unlimited authority. No errors of law or fact were found in AO's order, which represented a plausible interpretation after proper inquiry. Appeal decided in assessee's favor.
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