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 HC reversed the Tribunal's order regarding unexplained cash credits under Section 68, finding that the Tribunal had adopted a casual approach by merely following earlier orders without proper reasoning. The Court held that if the assessee fails to explain beneficiaries' identity, the entire amount should be added under Section 68, not just 0.15% as commission. The Court criticized the assessee's claim of providing accommodation entries without maintaining beneficiary details, noting this was implausible since the assessee must know withdrawal recipients. The Court directed ICAI to investigate professional misconduct by the CA involved and suggested PMLA authorities investigate potential money laundering. The HC maintained the 0.15% commission rate for identified credits only.
The HC reversed the Tribunal's order regarding unexplained cash credits under Section 68, finding that the Tribunal had adopted a casual approach by merely following earlier orders without proper reasoning. The Court held that if the assessee fails to explain beneficiaries' identity, the entire amount should be added under Section 68, not just 0.15% as commission. The Court criticized the assessee's claim of providing accommodation entries without maintaining beneficiary details, noting this was implausible since the assessee must know withdrawal recipients. The Court directed ICAI to investigate professional misconduct by the CA involved and suggested PMLA authorities investigate potential money laundering. The HC maintained the 0.15% commission rate for identified credits only.
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