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 order of CIT(A) and dismissed Revenue's appeals, rejecting additions under s.68 and s.69C. The Tribunal found the assessee had furnished corroborative documentary evidence - ledger extracts, sales register, invoices, bank statements, e-way bills, transport details and VAT returns - demonstrating genuine sales recorded in books. The AO's additions rested solely on an isolated statement of a third party without independent corroborative or substantive material, and AO did not controvert the documentary evidence. Accordingly, the Tribunal held the AO's reliance on the investigation wing's finding that a purchaser was bogus was insufficient to sustain additions, and directed deletion of the impugned additions.
ITAT upheld the order of CIT(A) and dismissed Revenue's appeals, rejecting additions under s.68 and s.69C. The Tribunal found the assessee had furnished corroborative documentary evidence - ledger extracts, sales register, invoices, bank statements, e-way bills, transport details and VAT returns - demonstrating genuine sales recorded in books. The AO's additions rested solely on an isolated statement of a third party without independent corroborative or substantive material, and AO did not controvert the documentary evidence. Accordingly, the Tribunal held the AO's reliance on the investigation wing's finding that a purchaser was bogus was insufficient to sustain additions, and directed deletion of the impugned additions.
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TaxTMI 
TaxTMI 
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