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...
ITAT held that the assessee's subscription scheme "Kuber Dhanvarsha" involving deposits ranging from Rs. 1,250 to Rs. 10,000 was fraudulent. The tribunal found the depositor addresses cryptic and unverifiable, with no genuine intention to return funds. The deposits were characterized as income under Section 28, not Section 68, due to lack of depositor genuineness proof. The tribunal concluded the scheme was designed to defraud innocent depositors, and the entire deposit collection constitutes taxable ill-gotten income. Consequently, the ITAT sustained the tax authorities' proposed additions and dismissed the assessee's appeal.
ITAT held that the assessee's subscription scheme "Kuber Dhanvarsha" involving deposits ranging from Rs. 1,250 to Rs. 10,000 was fraudulent. The tribunal found the depositor addresses cryptic and unverifiable, with no genuine intention to return funds. The deposits were characterized as income under Section 28, not Section 68, due to lack of depositor genuineness proof. The tribunal concluded the scheme was designed to defraud innocent depositors, and the entire deposit collection constitutes taxable ill-gotten income. Consequently, the ITAT sustained the tax authorities' proposed additions and dismissed the assessee's appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
