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...
The AT found evidence of hawala transactions through a recovered notebook containing daily business accounts, despite the appellant's retraction. The tribunal corroborated the evidence through multiple sources, including witness statements. Cross-examination was deemed unnecessary in quasi-judicial proceedings. The penalties were partially modified: for the primary appellant, penalties were reduced to Rs. 40,00,000 for Section 3(c), Rs. 60,00,000 for Section 3(a), and Rs. 40,00,000 for Section 3(b). For the employee, penalties were substantially reduced to Rs. 90,000 for Section 3(c), Rs. 1,00,000 for Section 3(a), and Rs. 90,000 for Section 3(b), recognizing his limited role in the transactions.
The AT found evidence of hawala transactions through a recovered notebook containing daily business accounts, despite the appellant's retraction. The tribunal corroborated the evidence through multiple sources, including witness statements. Cross-examination was deemed unnecessary in quasi-judicial proceedings. The penalties were partially modified: for the primary appellant, penalties were reduced to Rs. 40,00,000 for Section 3(c), Rs. 60,00,000 for Section 3(a), and Rs. 40,00,000 for Section 3(b). For the employee, penalties were substantially reduced to Rs. 90,000 for Section 3(c), Rs. 1,00,000 for Section 3(a), and Rs. 90,000 for Section 3(b), recognizing his limited role in the transactions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
