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...
ITAT allowed the assessee's appeal regarding bogus purchase additions. The assessee joined M/s. Gauri Construction as partner in AY 2011-12 when it converted from proprietorship to firm. Commercial tax authorities subsequently identified bogus transactions of M/s. Gauri Construction for AY 2010-11, which were incorrectly tagged to the assessee's PAN despite occurring before partnership formation. CIT(A) correctly determined that since all evidence related to M/s. Gauri Construction's transactions, the AO lacked justification for making adverse inferences against the assessee personally. ITAT upheld CIT(A)'s decision to delete the addition, finding no basis for attributing pre-partnership transactions to the individual assessee.
ITAT allowed the assessee's appeal regarding bogus purchase additions. The assessee joined M/s. Gauri Construction as partner in AY 2011-12 when it converted from proprietorship to firm. Commercial tax authorities subsequently identified bogus transactions of M/s. Gauri Construction for AY 2010-11, which were incorrectly tagged to the assessee's PAN despite occurring before partnership formation. CIT(A) correctly determined that since all evidence related to M/s. Gauri Construction's transactions, the AO lacked justification for making adverse inferences against the assessee personally. ITAT upheld CIT(A)'s decision to delete the addition, finding no basis for attributing pre-partnership transactions to the individual assessee.
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