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...
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The ITAT upheld the validity of the Assessment Order issued with a Document Identification Number (DIN) under Section 292B, dismissing the Assessee's technical objections. The Tribunal rejected the challenge to jurisdiction under Section 153D based on the timing of approval, finding no infirmity absent contrary evidence. Regarding additions under Section 69A for undisclosed foreign assets, the ITAT accepted the Assessee's evidence demonstrating that the bank account and portfolio belonged to a trust, not the Assessee individually, and that the source of funds was satisfactorily explained. Consequently, the additions were deleted. The Tribunal further held that jurisdiction under Section 153A was improperly assumed in the absence of incriminating material for the relevant year, rendering the assessment under Section 153A invalid. The appeal was allowed to the extent of deleting the additions and quashing the Section 153A assessment.
The ITAT upheld the validity of the Assessment Order issued with a Document Identification Number (DIN) under Section 292B, dismissing the Assessee's technical objections. The Tribunal rejected the challenge to jurisdiction under Section 153D based on the timing of approval, finding no infirmity absent contrary evidence. Regarding additions under Section 69A for undisclosed foreign assets, the ITAT accepted the Assessee's evidence demonstrating that the bank account and portfolio belonged to a trust, not the Assessee individually, and that the source of funds was satisfactorily explained. Consequently, the additions were deleted. The Tribunal further held that jurisdiction under Section 153A was improperly assumed in the absence of incriminating material for the relevant year, rendering the assessment under Section 153A invalid. The appeal was allowed to the extent of deleting the additions and quashing the Section 153A assessment.
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