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 addition to income based on search operation surrender cannot be sustained. No incriminating material was found during search and seizure action at assessee's premises. The statement under Section 132(4) was retracted with detailed explanations, and seized documents did not reveal any undisclosed transactions. The Assessing Officer cannot make additions solely on an unsupported alleged surrender, especially when no evidence substantiates the claim. Under the new legal framework for search assessments, incriminating material is mandatory for reopening assessments beyond three years. The tribunal ruled in favor of the assessee, effectively rejecting the revenue's proposed income addition.
ITAT held that the addition to income based on search operation surrender cannot be sustained. No incriminating material was found during search and seizure action at assessee's premises. The statement under Section 132(4) was retracted with detailed explanations, and seized documents did not reveal any undisclosed transactions. The Assessing Officer cannot make additions solely on an unsupported alleged surrender, especially when no evidence substantiates the claim. Under the new legal framework for search assessments, incriminating material is mandatory for reopening assessments beyond three years. The tribunal ruled in favor of the assessee, effectively rejecting the revenue's proposed income addition.
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TaxTMI 
TaxTMI 
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