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...
The ITAT dismissed the Revenue's appeals and allowed the assessee's appeals. It upheld the CIT(A)'s deletion of additions u/s. 68 in respect of unexplained credits, finding the entity was not a shell and there was no incriminating evidence to sustain the addition. With regard to assessment proceedings u/s. 153A and the addition of GP on alleged unaccounted sales, the Tribunal held extrapolation-based estimates unsustainable where no incriminating material supported suppression for the relevant year; accordingly the GP additions were disallowed. The Tribunal noted incriminating evidence existed for AYs 2020-21 and 2021-22 but not for the impugned assessment, resulting in relief to the assessee.
The ITAT dismissed the Revenue's appeals and allowed the assessee's appeals. It upheld the CIT(A)'s deletion of additions u/s. 68 in respect of unexplained credits, finding the entity was not a shell and there was no incriminating evidence to sustain the addition. With regard to assessment proceedings u/s. 153A and the addition of GP on alleged unaccounted sales, the Tribunal held extrapolation-based estimates unsustainable where no incriminating material supported suppression for the relevant year; accordingly the GP additions were disallowed. The Tribunal noted incriminating evidence existed for AYs 2020-21 and 2021-22 but not for the impugned assessment, resulting in relief to the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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