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 taxpayer's appeal for statistical purposes, remanding the matter to the Jurisdictional Assessing Officer for fresh examination. The tribunal held that the assessing authority erred in treating entire gross receipts as income under section 143(1) without considering allowable expenditures. The tribunal emphasized that income tax is chargeable on net income calculated per the Income Tax Act 1961, after deducting eligible expenditures under sections 37 or 57. The case was remitted back for verification of expenditure genuineness, with directions for reasonable opportunity of hearing to the assessee and substantiation of claims without unnecessary adjournments.
ITAT allowed the taxpayer's appeal for statistical purposes, remanding the matter to the Jurisdictional Assessing Officer for fresh examination. The tribunal held that the assessing authority erred in treating entire gross receipts as income under section 143(1) without considering allowable expenditures. The tribunal emphasized that income tax is chargeable on net income calculated per the Income Tax Act 1961, after deducting eligible expenditures under sections 37 or 57. The case was remitted back for verification of expenditure genuineness, with directions for reasonable opportunity of hearing to the assessee and substantiation of claims without unnecessary adjournments.
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TaxTMI 
TaxTMI 
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