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 no incriminating material was found during income tax search of the assessee on 2.1.2020 for a completed assessment year. Statutory documents like charge sheets in public domain cannot be considered incriminating evidence. Statements from three individuals were deemed bald and did not reveal undisclosed income. The approval under section 153D was granted mechanically without due application of mind, rendering the assessment void ab initio. Consequently, additions made by the Assessing Officer were deleted, and the assessment for Assessment Year 2011-12 was quashed based on the Supreme Court's ratio decidendi in Abhishar Buildwell case.
ITAT held that no incriminating material was found during income tax search of the assessee on 2.1.2020 for a completed assessment year. Statutory documents like charge sheets in public domain cannot be considered incriminating evidence. Statements from three individuals were deemed bald and did not reveal undisclosed income. The approval under section 153D was granted mechanically without due application of mind, rendering the assessment void ab initio. Consequently, additions made by the Assessing Officer were deleted, and the assessment for Assessment Year 2011-12 was quashed based on the Supreme Court's ratio decidendi in Abhishar Buildwell case.
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TaxTMI 
TaxTMI 
of 4918 
