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 held that the reopening of assessment u/s. 147 was invalid because the AO relied only on unspecified "information" from an internal portal without furnishing the actual material or reasons to the assessee, thereby failing to demonstrate subjective satisfaction or provide the basis for reopening. The AO did not correlate the undisclosed information with the assessee's transactions nor elicit statements based on that information. Consequently, additions u/s. 68 were untenable: the assessee produced purchase particulars, demat records and exchange sale documents which the AO neither controverted nor discredited in the assessment order. For these reasons the ITAT set aside the reopening and allowed the assessee's appeal.
ITAT held that the reopening of assessment u/s. 147 was invalid because the AO relied only on unspecified "information" from an internal portal without furnishing the actual material or reasons to the assessee, thereby failing to demonstrate subjective satisfaction or provide the basis for reopening. The AO did not correlate the undisclosed information with the assessee's transactions nor elicit statements based on that information. Consequently, additions u/s. 68 were untenable: the assessee produced purchase particulars, demat records and exchange sale documents which the AO neither controverted nor discredited in the assessment order. For these reasons the ITAT set aside the reopening and allowed the assessee's appeal.
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TaxTMI 
TaxTMI 
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