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 held that the assessee duly disclosed share holdings in a Hong Kong company during AY 2007-08, which was confirmed by prosecution and session courts. The tribunal noted no evidence of undisclosed investments or cash transactions despite a search. The appellate authority's order deleting additional income was affirmed, finding no procedural or substantive irregularities in the assessee's tax disclosures. The tribunal rejected revenue's contentions, emphasizing factual compliance with tax reporting requirements and absence of material evidence supporting undisclosed income claims.
ITAT held that the assessee duly disclosed share holdings in a Hong Kong company during AY 2007-08, which was confirmed by prosecution and session courts. The tribunal noted no evidence of undisclosed investments or cash transactions despite a search. The appellate authority's order deleting additional income was affirmed, finding no procedural or substantive irregularities in the assessee's tax disclosures. The tribunal rejected revenue's contentions, emphasizing factual compliance with tax reporting requirements and absence of material evidence supporting undisclosed income claims.
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TaxTMI 
TaxTMI 
of 4918 
