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 upheld the AO's disallowance under section 292C, finding no contemporaneous claim of expenses or liabilities during the survey and dismissing the assessee's Ground No.2; the addition stands. The Tribunal directed recalculation of allowable partners' remuneration under section 40(b) (Explanation 3) by computing book profit after adding back confirmed additions of Rs. 62,28,947 and adhoc disallowances of Rs. 15,620, and ordered the AO to allow the remuneration claim accordingly. The Bench held that income declared during survey is taxable as business income under section 28, hence section 115BBE, and provisions applicable to deemed unexplained credits are not attracted.
The ITAT upheld the AO's disallowance under section 292C, finding no contemporaneous claim of expenses or liabilities during the survey and dismissing the assessee's Ground No.2; the addition stands. The Tribunal directed recalculation of allowable partners' remuneration under section 40(b) (Explanation 3) by computing book profit after adding back confirmed additions of Rs. 62,28,947 and adhoc disallowances of Rs. 15,620, and ordered the AO to allow the remuneration claim accordingly. The Bench held that income declared during survey is taxable as business income under section 28, hence section 115BBE, and provisions applicable to deemed unexplained credits are not attracted.
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