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 deleted the addition under section 69A based on seized loose papers, finding the AO's reliance on uncorroborated scribblings insufficient to establish unexplained income. The tribunal noted the AO's failure to verify transactions with named individuals, one of whom denied involvement, rendering the addition founded on mere suspicion. Consequently, the addition and related interest were set aside. However, the tribunal upheld the disallowance of expenses and addition for unexplained cash, as the assessee did not contest the CIT(A)'s prior confirmation of these disallowances. Thus, the appeal succeeded only in deleting the addition under section 69A, while the other grounds were dismissed for lack of challenge.
The ITAT deleted the addition under section 69A based on seized loose papers, finding the AO's reliance on uncorroborated scribblings insufficient to establish unexplained income. The tribunal noted the AO's failure to verify transactions with named individuals, one of whom denied involvement, rendering the addition founded on mere suspicion. Consequently, the addition and related interest were set aside. However, the tribunal upheld the disallowance of expenses and addition for unexplained cash, as the assessee did not contest the CIT(A)'s prior confirmation of these disallowances. Thus, the appeal succeeded only in deleting the addition under section 69A, while the other grounds were dismissed for lack of challenge.
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TaxTMI 
TaxTMI 
of 4918 
