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 that unaccounted cash receipts ("on-money") discovered during seizure operations constituted taxable income despite subsequent property registration to other parties. The Tribunal rejected the assessee's claim to reduce Rs. 10,00,000 from the addition as the CIT(A) found only the payment method had changed, not the total amount. However, regarding taxation of cash receipts, the ITAT modified the CIT(A)'s 50% profit estimation to 45% of gross receipts, partially allowing the assessee's appeal. The Tribunal confirmed the validity of notice under section 148 without providing 7 days to reply under section 148A(b) since search and seizure operations were conducted after 01.04.2021, making the case exempt from section 148A requirements per the proviso.
The ITAT upheld that unaccounted cash receipts ("on-money") discovered during seizure operations constituted taxable income despite subsequent property registration to other parties. The Tribunal rejected the assessee's claim to reduce Rs. 10,00,000 from the addition as the CIT(A) found only the payment method had changed, not the total amount. However, regarding taxation of cash receipts, the ITAT modified the CIT(A)'s 50% profit estimation to 45% of gross receipts, partially allowing the assessee's appeal. The Tribunal confirmed the validity of notice under section 148 without providing 7 days to reply under section 148A(b) since search and seizure operations were conducted after 01.04.2021, making the case exempt from section 148A requirements per the proviso.
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TaxTMI 
TaxTMI 
of 4918 
