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...
ITAT upheld the CIT(A)'s deletion of an addition under s. 69C, finding the AO's treatment legally unsustainable. The AO ignored comprehensive documentary evidence submitted by the assessee - ledger entries, supplier invoices, delivery challans, inventory registers, bank remittances, vehicle entry/exit records, lorry receipts and warehouse log books - and did not dispute their veracity. The tribunal noted the supplier's GST cancellation postdated the challenged purchases, undermining the AO's sham-transaction assertion. Given the assessee's substantiation and the AO's failure to engage with or controvert the evidence, ITAT confirmed that the addition was unjustified and upheld relief granted by the CIT(A).
ITAT upheld the CIT(A)'s deletion of an addition under s. 69C, finding the AO's treatment legally unsustainable. The AO ignored comprehensive documentary evidence submitted by the assessee - ledger entries, supplier invoices, delivery challans, inventory registers, bank remittances, vehicle entry/exit records, lorry receipts and warehouse log books - and did not dispute their veracity. The tribunal noted the supplier's GST cancellation postdated the challenged purchases, undermining the AO's sham-transaction assertion. Given the assessee's substantiation and the AO's failure to engage with or controvert the evidence, ITAT confirmed that the addition was unjustified and upheld relief granted by the CIT(A).
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TaxTMI 
TaxTMI 
of 4918 
