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 upheld the Assessing Officer's (AO) original assessment, determining that the surrendered sum should be treated as business income rather than invoking special provisions under section 115BBE and 69A. The tribunal found the AO conducted a thorough examination of the assessee's survey statement, surrender letter, and income return, and applied due diligence in assessing the income. The tribunal concluded there was no procedural error or lack of enquiry in the original assessment, thereby rejecting the revision petition and deciding in favor of the assessee.
ITAT upheld the Assessing Officer's (AO) original assessment, determining that the surrendered sum should be treated as business income rather than invoking special provisions under section 115BBE and 69A. The tribunal found the AO conducted a thorough examination of the assessee's survey statement, surrender letter, and income return, and applied due diligence in assessing the income. The tribunal concluded there was no procedural error or lack of enquiry in the original assessment, thereby rejecting the revision petition and deciding in favor of the assessee.
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TaxTMI 
TaxTMI 
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