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 appeal concerning gross profit estimation after rejection of books of accounts for a livestock dealer. The assessee purchased animals from farmers and sold to slaughterhouses, conducting transactions primarily in cash without formal bills or vouchers due to the nature of the business. The coordinate bench in Salauddin Saifi established 0.5% as reasonable profit for this trade. The CIT(A) had enhanced the GP ratio based on comparable cases, but ITAT directed the AO to restrict GP to 0.5%. Since the assessee had already declared 0.6% GP, which exceeded the benchmark, ITAT directed retention of the declared rate, allowing the assessee's grounds and providing favorable relief.
ITAT allowed the appeal concerning gross profit estimation after rejection of books of accounts for a livestock dealer. The assessee purchased animals from farmers and sold to slaughterhouses, conducting transactions primarily in cash without formal bills or vouchers due to the nature of the business. The coordinate bench in Salauddin Saifi established 0.5% as reasonable profit for this trade. The CIT(A) had enhanced the GP ratio based on comparable cases, but ITAT directed the AO to restrict GP to 0.5%. Since the assessee had already declared 0.6% GP, which exceeded the benchmark, ITAT directed retention of the declared rate, allowing the assessee's grounds and providing favorable relief.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
