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 cash receipt of Rs. 7 lakhs for immovable property sale did not violate section 269SS. The unregistered agreement to sale, which subsequently culminated in a sale deed, was deemed valid. The department failed to verify the cash payment details or provide cogent reasons for rejecting the assessee's claim. No substantive evidence demonstrated a violation of statutory provisions. The tribunal found no merit in the penalty order and directed the Assessing Officer to delete the penalty. The appeal was allowed, with the CIT(A)'s procedural inconsistencies regarding appeal filing date also noted and dismissed.
ITAT held that cash receipt of Rs. 7 lakhs for immovable property sale did not violate section 269SS. The unregistered agreement to sale, which subsequently culminated in a sale deed, was deemed valid. The department failed to verify the cash payment details or provide cogent reasons for rejecting the assessee's claim. No substantive evidence demonstrated a violation of statutory provisions. The tribunal found no merit in the penalty order and directed the Assessing Officer to delete the penalty. The appeal was allowed, with the CIT(A)'s procedural inconsistencies regarding appeal filing date also noted and dismissed.
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TaxTMI 
TaxTMI 
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