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 allowed the assessee's appeal against additions made under section 68 read with section 115BBE regarding alleged bogus long-term capital gains. The Tribunal held that the AO's addition was untenable as it was based solely on an investigation report that was never shared with the assessee. The assessee had substantiated the legitimacy of the share transactions by providing evidence that shares were originally purchased in cash, physically delivered, later dematerialized, and eventually sold through proper channels with consideration received through banking channels. Following the precedent in Krishna Devi, the ITAT concluded that additions cannot be made merely on assumptions when transactions are properly documented through banking and demat accounts.
The ITAT allowed the assessee's appeal against additions made under section 68 read with section 115BBE regarding alleged bogus long-term capital gains. The Tribunal held that the AO's addition was untenable as it was based solely on an investigation report that was never shared with the assessee. The assessee had substantiated the legitimacy of the share transactions by providing evidence that shares were originally purchased in cash, physically delivered, later dematerialized, and eventually sold through proper channels with consideration received through banking channels. Following the precedent in Krishna Devi, the ITAT concluded that additions cannot be made merely on assumptions when transactions are properly documented through banking and demat accounts.
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TaxTMI 
TaxTMI 
of 4921 
