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 upheld the CIT(A)'s approach but dismissed Additional Ground No.1A, finding the Assessing Officer had relied on incriminating material seized from common premises of the group, thereby validating use of those materials. The Tribunal observed the AO's gross commission determination (1.28%) was excessive and, having regard to ITSC findings in the group's case, directed the AO to make a limited adjustment to the assessee's net profit by applying half the rate adopted by the ITSC. The resultant additional net profit rate is 0.0375% over the income declared in the return. Appeal disposed of against the revenue.
ITAT upheld the CIT(A)'s approach but dismissed Additional Ground No.1A, finding the Assessing Officer had relied on incriminating material seized from common premises of the group, thereby validating use of those materials. The Tribunal observed the AO's gross commission determination (1.28%) was excessive and, having regard to ITSC findings in the group's case, directed the AO to make a limited adjustment to the assessee's net profit by applying half the rate adopted by the ITSC. The resultant additional net profit rate is 0.0375% over the income declared in the return. Appeal disposed of against the revenue.
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TaxTMI 
TaxTMI 
of 4918 
