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 partially allowed the appeal concerning unexplained investment under Section 69. The Tribunal sustained the addition of bullion weighing 329 grams valued at Rs. 8,89,170/- and scaled down the addition of gold jewelry from 437.700 grams to 62.962 grams valued at Rs. 1,71,886/-. The decision was based on the assessee's inability to substantiate the source of gold jewelry found in a jointly held locker, with the Tribunal directing the Assessing Officer to restrict the addition accordingly, following judicial precedents and CBDT instructions.
ITAT partially allowed the appeal concerning unexplained investment under Section 69. The Tribunal sustained the addition of bullion weighing 329 grams valued at Rs. 8,89,170/- and scaled down the addition of gold jewelry from 437.700 grams to 62.962 grams valued at Rs. 1,71,886/-. The decision was based on the assessee's inability to substantiate the source of gold jewelry found in a jointly held locker, with the Tribunal directing the Assessing Officer to restrict the addition accordingly, following judicial precedents and CBDT instructions.
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TaxTMI 
TaxTMI 
of 4918 
