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 the addition of unexplained unsecured loans under section 68, finding the assessee successfully established the identity, creditworthiness, and genuineness of the lenders, which were private limited companies with valid PANs and audited financial statements. The loans were routed through banking channels and repaid within the same assessment year, negating the presumption of unaccounted income. The issuance of notices under section 148 was held valid, having been preceded by proper recording of reasons and approval from the Pr. CIT. The revenue's appeal was dismissed, as the assessee discharged the onus regarding the loans' legitimacy and repayment, and no adverse inference was warranted. Consequently, no addition under section 68 was justified.
The ITAT upheld the deletion of the addition of unexplained unsecured loans under section 68, finding the assessee successfully established the identity, creditworthiness, and genuineness of the lenders, which were private limited companies with valid PANs and audited financial statements. The loans were routed through banking channels and repaid within the same assessment year, negating the presumption of unaccounted income. The issuance of notices under section 148 was held valid, having been preceded by proper recording of reasons and approval from the Pr. CIT. The revenue's appeal was dismissed, as the assessee discharged the onus regarding the loans' legitimacy and repayment, and no adverse inference was warranted. Consequently, no addition under section 68 was justified.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
