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...
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The ITAT allowed Revenue's legal contention that documents seized from a third party could be considered in proceedings under s.153A where the assessee was also a searched person, holding s.153C inapplicable to that extent and setting aside the CIT(A)'s exclusion of such documents. However, on merits the Tribunal dismissed Revenue's additions under s.69B for completed assessments where no incriminating material was seized from the assessee's premises, finding the AO relied solely on third-party papers and granting relief to the assessee. The Tribunal upheld deletion of disallowance under s.40A(2)(b) for lack of objective material and accepted the CIT(A)'s telescoping of land-investment additions, rejecting Revenue's broader challenge.
The ITAT allowed Revenue's legal contention that documents seized from a third party could be considered in proceedings under s.153A where the assessee was also a searched person, holding s.153C inapplicable to that extent and setting aside the CIT(A)'s exclusion of such documents. However, on merits the Tribunal dismissed Revenue's additions under s.69B for completed assessments where no incriminating material was seized from the assessee's premises, finding the AO relied solely on third-party papers and granting relief to the assessee. The Tribunal upheld deletion of disallowance under s.40A(2)(b) for lack of objective material and accepted the CIT(A)'s telescoping of land-investment additions, rejecting Revenue's broader challenge.
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