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...
ITAT upheld the AO's addition under Section 69 as unexplained investment, rejecting the assessee's contentions. The tribunal found that the seized incriminating material carried a presumption of correctness under Section 292C of the Income Tax Act. The proceedings were governed by preponderance of probability, not criminal standard of proof beyond reasonable doubt. The assessee's arguments regarding criminal court proceedings and natural justice were dismissed. The tribunal emphasized that the Income Tax Act is a complete code, and the department's findings were based on conclusive evidence. The impugned additions for multiple assessment years were sustained, with the decision rendered in favor of the revenue.
ITAT upheld the AO's addition under Section 69 as unexplained investment, rejecting the assessee's contentions. The tribunal found that the seized incriminating material carried a presumption of correctness under Section 292C of the Income Tax Act. The proceedings were governed by preponderance of probability, not criminal standard of proof beyond reasonable doubt. The assessee's arguments regarding criminal court proceedings and natural justice were dismissed. The tribunal emphasized that the Income Tax Act is a complete code, and the department's findings were based on conclusive evidence. The impugned additions for multiple assessment years were sustained, with the decision rendered in favor of the revenue.
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