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 addition of unexplained cash credits under section 68, finding that the assessee failed to discharge the onus of proving the identity, genuineness, and creditworthiness of the investor companies. Despite furnishing primary documents such as ITRs, bank statements, and confirmations, the assessee could not establish the financial capacity of the lenders, whose bank transactions indicated circular movement of funds. The failure to produce the directors of the creditor companies before the AO was deemed a deliberate attempt to conceal facts. The tribunal rejected the assessee's reliance on precedents favoring first-year business and held that mere filing of basic documents does not satisfy the evidentiary burden under section 68. Consequently, the cash credits were rightly treated as income from undisclosed sources, and the CIT(A)'s order confirming the AO's addition was affirmed.
The ITAT upheld the addition of unexplained cash credits under section 68, finding that the assessee failed to discharge the onus of proving the identity, genuineness, and creditworthiness of the investor companies. Despite furnishing primary documents such as ITRs, bank statements, and confirmations, the assessee could not establish the financial capacity of the lenders, whose bank transactions indicated circular movement of funds. The failure to produce the directors of the creditor companies before the AO was deemed a deliberate attempt to conceal facts. The tribunal rejected the assessee's reliance on precedents favoring first-year business and held that mere filing of basic documents does not satisfy the evidentiary burden under section 68. Consequently, the cash credits were rightly treated as income from undisclosed sources, and the CIT(A)'s order confirming the AO's addition was affirmed.
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TaxTMI 
TaxTMI 
of 4918 
