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...
AT confirmed seized cash of Rs. 98.93 crores and 166.27 kg gold bullion as benami property under Section 2(9)(D) of PBPTA, overturning the Adjudicating Authority's decision. The Tribunal found the respondent firm's explanation regarding unrecorded sand sale proceeds unconvincing, particularly noting the timing of seizures post-demonetization and simultaneous filing of ITRs for two assessment years. Partners' contradictory statements and retractions undermined credibility. The substantial unaccounted assets, absence from regular books, and lack of proper business records indicated benami transactions where respondent merely lent their name while concealing actual beneficial owners. Appeal allowed, provisional attachment order upheld.
AT confirmed seized cash of Rs. 98.93 crores and 166.27 kg gold bullion as benami property under Section 2(9)(D) of PBPTA, overturning the Adjudicating Authority's decision. The Tribunal found the respondent firm's explanation regarding unrecorded sand sale proceeds unconvincing, particularly noting the timing of seizures post-demonetization and simultaneous filing of ITRs for two assessment years. Partners' contradictory statements and retractions undermined credibility. The substantial unaccounted assets, absence from regular books, and lack of proper business records indicated benami transactions where respondent merely lent their name while concealing actual beneficial owners. Appeal allowed, provisional attachment order upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
