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 upheld the CIT(A)'s deletion of additions relating to unaccounted sales under the "V" series for AY 2014-15 to 2017-18, rejecting the AO's extrapolation of a 17% unaccounted income ratio from a limited three-month period to earlier years. The Tribunal found the extrapolation speculative and unsupported by corroborative evidence, particularly as the statements relied upon were retracted and no supporting material such as seized data, unexplained investments, or asset acquisitions was found. The books of account were not rejected, rendering the AO's estimation invalid. For AY 2018-19, the AO's claim of suppression beyond the admitted amount was also dismissed due to lack of evidence. Consequently, all revenue appeals were dismissed, affirming the correctness of the CIT(A)'s orders on merit.
The ITAT upheld the CIT(A)'s deletion of additions relating to unaccounted sales under the "V" series for AY 2014-15 to 2017-18, rejecting the AO's extrapolation of a 17% unaccounted income ratio from a limited three-month period to earlier years. The Tribunal found the extrapolation speculative and unsupported by corroborative evidence, particularly as the statements relied upon were retracted and no supporting material such as seized data, unexplained investments, or asset acquisitions was found. The books of account were not rejected, rendering the AO's estimation invalid. For AY 2018-19, the AO's claim of suppression beyond the admitted amount was also dismissed due to lack of evidence. Consequently, all revenue appeals were dismissed, affirming the correctness of the CIT(A)'s orders on merit.
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TaxTMI 
TaxTMI 
of 4918 
