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 deletion of additions made by the AO on account of alleged bogus expenses and purchases. The Tribunal rejected the Revenue's attempt to sustain protective disallowance of contract expenses, relying on established precedent that such additions apply only when there is genuine doubt as to the taxable recipient of income. The AO's disallowance of purchases was also affirmed to be unsustainable, as it was based on unproven accommodation entries without supporting evidence. Consequently, the ITAT confirmed the CIT(A)'s order deleting the impugned disallowances, ruling in favor of the assessee and against the Revenue.
The ITAT upheld the deletion of additions made by the AO on account of alleged bogus expenses and purchases. The Tribunal rejected the Revenue's attempt to sustain protective disallowance of contract expenses, relying on established precedent that such additions apply only when there is genuine doubt as to the taxable recipient of income. The AO's disallowance of purchases was also affirmed to be unsustainable, as it was based on unproven accommodation entries without supporting evidence. Consequently, the ITAT confirmed the CIT(A)'s order deleting the impugned disallowances, ruling in favor of the assessee and against the Revenue.
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TaxTMI 
TaxTMI 
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