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 allowed the appeal, setting aside the CIT(A)'s order and deleting additions under Section 69. The tribunal found critical procedural and evidentiary defects in the assessment order, specifically noting that the Assessing Officer (AO) relied solely on an incomplete statement without seeking explanations from directors, failed to establish concrete evidence of unaccounted investments, and improperly concluded deposits were made by directors based on minor clerical errors in forms. The tribunal emphasized that the burden of proof lies with the revenue authority, which failed to substantiate allegations of undisclosed investments made by the assessee. The order was decided in favor of the assessee, effectively quashing the disputed tax additions.
ITAT allowed the appeal, setting aside the CIT(A)'s order and deleting additions under Section 69. The tribunal found critical procedural and evidentiary defects in the assessment order, specifically noting that the Assessing Officer (AO) relied solely on an incomplete statement without seeking explanations from directors, failed to establish concrete evidence of unaccounted investments, and improperly concluded deposits were made by directors based on minor clerical errors in forms. The tribunal emphasized that the burden of proof lies with the revenue authority, which failed to substantiate allegations of undisclosed investments made by the assessee. The order was decided in favor of the assessee, effectively quashing the disputed tax additions.
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TaxTMI 
TaxTMI 
of 4918 
