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...
ITAT allowed the assessee's appeal, holding that amounts standing to credit in a foreign bank account cannot be taxed absent a real and intimate business connection with India. The Tribunal found no direct evidence of business activity in India and rejected the DRP's contention that an Indian address or mere credit in the HSBC Geneva account established a taxable nexus. The impugned addition under the Income Tax Act was set aside for lack of legal basis and requisite causal link between any activity in India and accrual of income to the non-resident. Directions were issued to delete the addition and restore the assessment accordingly.
ITAT allowed the assessee's appeal, holding that amounts standing to credit in a foreign bank account cannot be taxed absent a real and intimate business connection with India. The Tribunal found no direct evidence of business activity in India and rejected the DRP's contention that an Indian address or mere credit in the HSBC Geneva account established a taxable nexus. The impugned addition under the Income Tax Act was set aside for lack of legal basis and requisite causal link between any activity in India and accrual of income to the non-resident. Directions were issued to delete the addition and restore the assessment accordingly.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
