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 Assessment Officer's (AO) order regarding unexplained cash deposits in the assessee's bank account. The tribunal found no credible evidence supporting the assessee's claim that the deposits represented sale proceeds from her father's property. The assessee failed to provide documentary proof or explain the source of 18 cash deposits made between 04/05/2010 and 08/13/2010. The reopening of assessment under Section 147 was deemed valid, as the AO had proper reason to believe income had escaped assessment. The tribunal emphasized that at the reassessment stage, the existence of material is crucial, not its adequacy. Consequently, the assessee's appeal was dismissed, confirming the original tax demand.
ITAT upheld the Assessment Officer's (AO) order regarding unexplained cash deposits in the assessee's bank account. The tribunal found no credible evidence supporting the assessee's claim that the deposits represented sale proceeds from her father's property. The assessee failed to provide documentary proof or explain the source of 18 cash deposits made between 04/05/2010 and 08/13/2010. The reopening of assessment under Section 147 was deemed valid, as the AO had proper reason to believe income had escaped assessment. The tribunal emphasized that at the reassessment stage, the existence of material is crucial, not its adequacy. Consequently, the assessee's appeal was dismissed, confirming the original tax demand.
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