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 analyzed cash deposit during demonetization, finding no unexplained income. Assessee declared total sales of Rs. 49,03,470/- including cash sales of Rs. 30,25,930/-, with VAT returns matching ITR declarations. Independent VAT authorities confirmed no errors. Cash deposited originated from legitimate sales proceeds existing prior to demonetization announcement. Following precedent in similar cases, ITAT deleted addition under Section 69A, rejecting tax authorities' conjecture of undisclosed income. Tribunal ruled in favor of assessee, holding that taxing same income twice would be improper and unsupported by evidence.
ITAT analyzed cash deposit during demonetization, finding no unexplained income. Assessee declared total sales of Rs. 49,03,470/- including cash sales of Rs. 30,25,930/-, with VAT returns matching ITR declarations. Independent VAT authorities confirmed no errors. Cash deposited originated from legitimate sales proceeds existing prior to demonetization announcement. Following precedent in similar cases, ITAT deleted addition under Section 69A, rejecting tax authorities' conjecture of undisclosed income. Tribunal ruled in favor of assessee, holding that taxing same income twice would be improper and unsupported by evidence.
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