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 allowed the assessee's appeal, holding that amounts credited by the employer company constituted salary and not deemed dividend under s. 2(22)(e), and therefore no addition was warranted; the tribunal accepted the assessee's filed return and computation as evidence of salary receipt. The tribunal further held that additions under s. 68 (and s. 69A) for unexplained cash credits were unjustified where the assessee adduced an explanation and the AO failed to discharge the evidentiary burden to the contrary, and accordingly deleted those additions. Net result: all contested additions were deleted and the appeal was allowed in favour of the assessee.
ITAT allowed the assessee's appeal, holding that amounts credited by the employer company constituted salary and not deemed dividend under s. 2(22)(e), and therefore no addition was warranted; the tribunal accepted the assessee's filed return and computation as evidence of salary receipt. The tribunal further held that additions under s. 68 (and s. 69A) for unexplained cash credits were unjustified where the assessee adduced an explanation and the AO failed to discharge the evidentiary burden to the contrary, and accordingly deleted those additions. Net result: all contested additions were deleted and the appeal was allowed in favour of the assessee.
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TaxTMI 
TaxTMI 
of 4918 
