Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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The ITAT held that the AO exceeded the limited scope of scrutiny authorized for examining cash deposits during demonetization without obtaining requisite PCIT approval, violating Instruction No.225/402/2018/ITA.II. The AO's addition under section 68 was quashed as the assessee provided a reconciliation of bank credits which the CIT(A) neither challenged nor disproved. The CIT(A) erred in confirming an addition based on discrepancies unrelated to the limited scrutiny parameters and failed to consider that cash deposits during demonetization were minimal. Consequently, the ITAT deleted the addition of Rs. 1,14,43,309/-, finding the AO's and CIT(A)'s orders unsustainable, and allowed the assessee's appeal.
The ITAT held that the AO exceeded the limited scope of scrutiny authorized for examining cash deposits during demonetization without obtaining requisite PCIT approval, violating Instruction No.225/402/2018/ITA.II. The AO's addition under section 68 was quashed as the assessee provided a reconciliation of bank credits which the CIT(A) neither challenged nor disproved. The CIT(A) erred in confirming an addition based on discrepancies unrelated to the limited scrutiny parameters and failed to consider that cash deposits during demonetization were minimal. Consequently, the ITAT deleted the addition of Rs. 1,14,43,309/-, finding the AO's and CIT(A)'s orders unsustainable, and allowed the assessee's appeal.
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