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...
The ITAT upheld the CIT(A)'s deletion of additions made by the AO under s.68 regarding share application money/premium received from non-resident investors. The Tribunal found the assessee had sufficiently proved the identity and creditworthiness of investors and transaction genuineness. Regarding trade payables, the ITAT determined s.68 was inapplicable as the disputed amounts represented outstanding liabilities for purchases rather than unexplained credits in the assessee's books. Following Kulwinder Singh, the Tribunal confirmed that s.68 provisions do not apply to amounts representing credit purchases. The Revenue's appeal was accordingly dismissed on both grounds.
The ITAT upheld the CIT(A)'s deletion of additions made by the AO under s.68 regarding share application money/premium received from non-resident investors. The Tribunal found the assessee had sufficiently proved the identity and creditworthiness of investors and transaction genuineness. Regarding trade payables, the ITAT determined s.68 was inapplicable as the disputed amounts represented outstanding liabilities for purchases rather than unexplained credits in the assessee's books. Following Kulwinder Singh, the Tribunal confirmed that s.68 provisions do not apply to amounts representing credit purchases. The Revenue's appeal was accordingly dismissed on both grounds.
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TaxTMI 
TaxTMI 
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