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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ITAT held that the addition under Section 68 for unsecured loans was inappropriate. The tribunal found the assessee established creditor identity through PAN, creditworthiness via bank statements and ITRs, and confirmed loan origin from creditors' own bank accounts. The Assessing Officer's addition was based on mere suspicion without clinching evidence proving the funds did not genuinely belong to the stated creditors. The tribunal deleted the contested addition, ruling in favor of the assessee based on comprehensive documentary evidence demonstrating loan authenticity and creditor legitimacy.
ITAT held that the addition under Section 68 for unsecured loans was inappropriate. The tribunal found the assessee established creditor identity through PAN, creditworthiness via bank statements and ITRs, and confirmed loan origin from creditors' own bank accounts. The Assessing Officer's addition was based on mere suspicion without clinching evidence proving the funds did not genuinely belong to the stated creditors. The tribunal deleted the contested addition, ruling in favor of the assessee based on comprehensive documentary evidence demonstrating loan authenticity and creditor legitimacy.
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