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...
The ITAT held that the reopening of assessment based on alleged unexplained cash deposits exceeding Rs. 1 lakh was unjustified due to factual inaccuracies and lack of application of mind by the AO. The AO's reasons were founded on incorrect figures and failed to establish a nexus between the assessee's declared turnover and the purported information. The assessee provided detailed records substantiating the deposits as legitimate sale proceeds, corroborated by bank statements and inventory data, which the AO disregarded without proper analysis. Consequently, the ITAT upheld the CIT(A)'s decision to quash the reassessment, finding no merit in the Revenue's appeal. The unexplained cash credit allegation was dismissed for lack of evidentiary support and improper evaluation by the AO.
The ITAT held that the reopening of assessment based on alleged unexplained cash deposits exceeding Rs. 1 lakh was unjustified due to factual inaccuracies and lack of application of mind by the AO. The AO's reasons were founded on incorrect figures and failed to establish a nexus between the assessee's declared turnover and the purported information. The assessee provided detailed records substantiating the deposits as legitimate sale proceeds, corroborated by bank statements and inventory data, which the AO disregarded without proper analysis. Consequently, the ITAT upheld the CIT(A)'s decision to quash the reassessment, finding no merit in the Revenue's appeal. The unexplained cash credit allegation was dismissed for lack of evidentiary support and improper evaluation by the AO.
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TaxTMI 
TaxTMI 
of 4918 
