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 adjudicated two key issues involving capital account and sundry creditors. The tribunal found material misunderstandings by the Assessing Officer regarding capital account balances, distinguishing between personal and business balance sheets. Regarding sundry creditors, the tribunal determined the change was merely nomenclature without substantive financial alteration. ITAT comprehensively set aside CIT(A)'s order, directing the Assessing Officer to delete both contested additions. The tribunal critically emphasized proper fact appreciation and rejected mechanical additions without substantive evidence. The final outcome was decisively in favor of the assessee, effectively nullifying the disputed tax assessments.
ITAT adjudicated two key issues involving capital account and sundry creditors. The tribunal found material misunderstandings by the Assessing Officer regarding capital account balances, distinguishing between personal and business balance sheets. Regarding sundry creditors, the tribunal determined the change was merely nomenclature without substantive financial alteration. ITAT comprehensively set aside CIT(A)'s order, directing the Assessing Officer to delete both contested additions. The tribunal critically emphasized proper fact appreciation and rejected mechanical additions without substantive evidence. The final outcome was decisively in favor of the assessee, effectively nullifying the disputed tax assessments.
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TaxTMI 
TaxTMI 
of 4918 
