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 ruled on multiple taxation issues involving unexplained cash deposits during demonetization. The tribunal sustained addition u/s 69A regarding cash deposits, finding the assessee's explanations unconvincing. Bad debt claims were partially allowed under section 36(1)(vii). The tribunal rejected the assessee's books of accounts and applied a minimal gross profit percentage of 0.1%. Notional commission additions were deleted. Regarding section 115BBE, the tribunal followed precedent limiting 60% tax rate to transactions from 01.04.2017 onwards, thereby restricting tax to 30% for earlier periods. Overall, the decision partially favored the assessee while upholding significant tax adjustments related to unexplained cash deposits during demonetization.
ITAT ruled on multiple taxation issues involving unexplained cash deposits during demonetization. The tribunal sustained addition u/s 69A regarding cash deposits, finding the assessee's explanations unconvincing. Bad debt claims were partially allowed under section 36(1)(vii). The tribunal rejected the assessee's books of accounts and applied a minimal gross profit percentage of 0.1%. Notional commission additions were deleted. Regarding section 115BBE, the tribunal followed precedent limiting 60% tax rate to transactions from 01.04.2017 onwards, thereby restricting tax to 30% for earlier periods. Overall, the decision partially favored the assessee while upholding significant tax adjustments related to unexplained cash deposits during demonetization.
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TaxTMI 
TaxTMI 
of 4918 
