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...
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The ITAT rejected revenue's appeal, affirming CIT(A)'s findings across multiple grounds. The tribunal dismissed revenue's challenges regarding income estimation, book of accounts rejection, and profit rate determination. Key holdings included: (1) When books are rejected and net profit estimated, no further additions can be made from the same rejected books, (2) Only real income should be taxed, not notional income, (3) Differences in form 26AS and book entries were adequately explained, and (4) The profit rate of 0.11% was consistent with coordinated bench precedent. The tribunal found no merit in revenue's grounds and dismissed all appeals, maintaining the lower appellate authority's favorable findings for the assessee.
The ITAT rejected revenue's appeal, affirming CIT(A)'s findings across multiple grounds. The tribunal dismissed revenue's challenges regarding income estimation, book of accounts rejection, and profit rate determination. Key holdings included: (1) When books are rejected and net profit estimated, no further additions can be made from the same rejected books, (2) Only real income should be taxed, not notional income, (3) Differences in form 26AS and book entries were adequately explained, and (4) The profit rate of 0.11% was consistent with coordinated bench precedent. The tribunal found no merit in revenue's grounds and dismissed all appeals, maintaining the lower appellate authority's favorable findings for the assessee.
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