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 HC upheld the Tribunal's decision that purchases under section 69C could not be treated as bogus despite unverifiable sources. The assessee substantiated the purchases through daily stock registers and production records (RG-23A and RG-23C), verified by the auditor and included in the TAR. Although notices under section 133(6) issued to the other party remained uncomplied and the party was not found at the recorded address, these facts were not disclosed to the assessee prior to the assessment order. Given the transactions were seven years old and the possibility of address changes, the AO did not dispute these circumstances. Consequently, the HC affirmed that the AO could not invoke section 69C, confirming the legitimacy of the purchases and rejecting the claim of bogus transactions.
The HC upheld the Tribunal's decision that purchases under section 69C could not be treated as bogus despite unverifiable sources. The assessee substantiated the purchases through daily stock registers and production records (RG-23A and RG-23C), verified by the auditor and included in the TAR. Although notices under section 133(6) issued to the other party remained uncomplied and the party was not found at the recorded address, these facts were not disclosed to the assessee prior to the assessment order. Given the transactions were seven years old and the possibility of address changes, the AO did not dispute these circumstances. Consequently, the HC affirmed that the AO could not invoke section 69C, confirming the legitimacy of the purchases and rejecting the claim of bogus transactions.
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