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 directed deletion of additions made under s.69A, holding that undocumented loose paper found at a third party's residence could not sustain an unexplained income addition against the assessee. The Tribunal found the AO's reliance on unsubstantiated inference from initials and an audio recording insufficient: the seized paper was undated and thus presumptively related to the year of search (FY 2020-21/AY 2021-22), not the assessment year to which the additions were made; no cash or corroborative documents were seized from the assessee; no enquiries were pursued concerning running bills; and the audio had no nexus to the assessee. Accordingly, additions based on the seized entries were deleted and grounds 1-3 were allowed.
ITAT directed deletion of additions made under s.69A, holding that undocumented loose paper found at a third party's residence could not sustain an unexplained income addition against the assessee. The Tribunal found the AO's reliance on unsubstantiated inference from initials and an audio recording insufficient: the seized paper was undated and thus presumptively related to the year of search (FY 2020-21/AY 2021-22), not the assessment year to which the additions were made; no cash or corroborative documents were seized from the assessee; no enquiries were pursued concerning running bills; and the audio had no nexus to the assessee. Accordingly, additions based on the seized entries were deleted and grounds 1-3 were allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
