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 upheld CIT(A)'s finding regarding unaccounted sales, dismissing Revenue's appeal. The tribunal determined that a substantial portion of allegedly unaccounted sales were already recorded in the assessee's books. Given the minimal volume of transactions with the specific party and verified accounting, the tribunal concluded that only the gross profit rate could be applied to potentially unaccounted sales. The decision emphasized that without challenging purchase records, entire sales cannot be summarily added as unaccounted. Consequently, the tribunal applied the disclosed gross profit rate reasonably and rejected the Revenue's broader claim of complete sales addition.
ITAT upheld CIT(A)'s finding regarding unaccounted sales, dismissing Revenue's appeal. The tribunal determined that a substantial portion of allegedly unaccounted sales were already recorded in the assessee's books. Given the minimal volume of transactions with the specific party and verified accounting, the tribunal concluded that only the gross profit rate could be applied to potentially unaccounted sales. The decision emphasized that without challenging purchase records, entire sales cannot be summarily added as unaccounted. Consequently, the tribunal applied the disclosed gross profit rate reasonably and rejected the Revenue's broader claim of complete sales addition.
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TaxTMI 
TaxTMI 
of 4918 
