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 several key rulings against the Revenue's appeals. The Tribunal dismissed multiple grounds raised by the tax department, including challenges to discount calculations, alleged bogus purchases, unexplained loans, and undisclosed cash receipts. Notably, the ITAT found insufficient evidence to substantiate the Assessing Officer's allegations of on-money receipts and deemed dividends. The Tribunal consistently emphasized the need for concrete proof and rejected ad hoc additions. Most significantly, the ITAT supported the CIT(A)'s findings, finding no material to disturb previous deletions of tax additions. The Revenue's appeals were systematically dismissed across various grounds, reinforcing procedural fairness and evidentiary standards in tax assessment.
ITAT upheld several key rulings against the Revenue's appeals. The Tribunal dismissed multiple grounds raised by the tax department, including challenges to discount calculations, alleged bogus purchases, unexplained loans, and undisclosed cash receipts. Notably, the ITAT found insufficient evidence to substantiate the Assessing Officer's allegations of on-money receipts and deemed dividends. The Tribunal consistently emphasized the need for concrete proof and rejected ad hoc additions. Most significantly, the ITAT supported the CIT(A)'s findings, finding no material to disturb previous deletions of tax additions. The Revenue's appeals were systematically dismissed across various grounds, reinforcing procedural fairness and evidentiary standards in tax assessment.
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TaxTMI 
TaxTMI 
of 4918 
