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 set aside CIT(A)'s order deleting additions towards un-reconciled payments from Vienna bank account and remitted matter to AO for fresh consideration. Tribunal found valid nexus between reopening reasons based on confession statement and escaped income, noting appellant's admission of Rs. 1230 crores understated liability. AO's additions were based on KPMG forensic audit report without providing copy to assessee for rebuttal. Since related company's assessment was set aside by High Court for considering re-casted books of accounts, and intra-group transactions would impact appellant's income, fresh assessment required after considering re-casted accounts and forensic audit findings. Both assessee's and revenue's appeals allowed for statistical purposes.
ITAT set aside CIT(A)'s order deleting additions towards un-reconciled payments from Vienna bank account and remitted matter to AO for fresh consideration. Tribunal found valid nexus between reopening reasons based on confession statement and escaped income, noting appellant's admission of Rs. 1230 crores understated liability. AO's additions were based on KPMG forensic audit report without providing copy to assessee for rebuttal. Since related company's assessment was set aside by High Court for considering re-casted books of accounts, and intra-group transactions would impact appellant's income, fresh assessment required after considering re-casted accounts and forensic audit findings. Both assessee's and revenue's appeals allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
