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...
The ITAT quashed assessment orders for AYs 2014-15 and 2015-16 as time-barred, finding that the AO's reference to special audit under s.142(2A) was void ab initio since statutory conditions were not satisfied. Consequently, the extended time limit under s.153A was inapplicable, rendering the assessments invalid due to limitation. However, regarding additions under s.69 for unexplained payments, the Tribunal upheld the CIT(A)'s decision sustaining the AO's additions, noting the 4-year gap between alleged advance receipts and payments, and the appellant's failure to establish the source of payments from known income sources.
The ITAT quashed assessment orders for AYs 2014-15 and 2015-16 as time-barred, finding that the AO's reference to special audit under s.142(2A) was void ab initio since statutory conditions were not satisfied. Consequently, the extended time limit under s.153A was inapplicable, rendering the assessments invalid due to limitation. However, regarding additions under s.69 for unexplained payments, the Tribunal upheld the CIT(A)'s decision sustaining the AO's additions, noting the 4-year gap between alleged advance receipts and payments, and the appellant's failure to establish the source of payments from known income sources.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
