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...
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ITAT allowed the assessee's appeal, deleting additions made under sections 69 and 56 for alleged cash loan and notional interest. The tribunal found no incriminating material in the assessee's possession during search proceedings. The additions were deemed beyond jurisdictional scope under section 153A, as no substantive evidence supported claims of loan advancement or unexplained assets. The tribunal noted the loan allegations were based on presumptions involving third parties, and the jewellery additions were reasonable given the family's size. Following precedential guidelines, the tribunal comprehensively rejected revenue's contentions and provided full relief to the assessee.
ITAT allowed the assessee's appeal, deleting additions made under sections 69 and 56 for alleged cash loan and notional interest. The tribunal found no incriminating material in the assessee's possession during search proceedings. The additions were deemed beyond jurisdictional scope under section 153A, as no substantive evidence supported claims of loan advancement or unexplained assets. The tribunal noted the loan allegations were based on presumptions involving third parties, and the jewellery additions were reasonable given the family's size. Following precedential guidelines, the tribunal comprehensively rejected revenue's contentions and provided full relief to the assessee.
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