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...
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ITAT set aside CIT(A) order and remanded assessment u/s 144 back to AO for de novo proceedings. Deceased assessee failed to file return for AY 2017-18, resulting in best judgment assessment with additions u/s 69A for specified bank notes deposited during demonetization and business income estimated at 8%. Assessee was hospitalized in ICU due to severe diabetes and stroke when assessment order was passed, subsequently dying on 18.05.2021. ITAT found denial of proper opportunity violated natural justice principles. Relying on TIN Box Co precedent, tribunal directed AO to conduct fresh assessment after providing adequate hearing opportunity. Assessee's representative undertook to substantiate SBN sources and challenge 8% business income estimation. Penalties u/s 271B and 271AAC(1) also remanded for fresh consideration post de novo assessment.
ITAT set aside CIT(A) order and remanded assessment u/s 144 back to AO for de novo proceedings. Deceased assessee failed to file return for AY 2017-18, resulting in best judgment assessment with additions u/s 69A for specified bank notes deposited during demonetization and business income estimated at 8%. Assessee was hospitalized in ICU due to severe diabetes and stroke when assessment order was passed, subsequently dying on 18.05.2021. ITAT found denial of proper opportunity violated natural justice principles. Relying on TIN Box Co precedent, tribunal directed AO to conduct fresh assessment after providing adequate hearing opportunity. Assessee's representative undertook to substantiate SBN sources and challenge 8% business income estimation. Penalties u/s 271B and 271AAC(1) also remanded for fresh consideration post de novo assessment.
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