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 upholds validity of reopening under s.147 of the Income-tax Act, finding that the AO had prima facie material (undisclosed bank account and substantial unexplained deposits during demonetisation) to infer escapement of income; CIT(A)'s detailed reasons were not controverted by the assessee and sanction under s.151 was effectively accorded. Grounds challenging jurisdictional reopening are dismissed. Reassessment was within the four-year period, so proviso to s.147 is inapplicable. Pursuant to the Explanation to s.147, AO possessed authority to examine and assess deposits beyond the original reasons; deposits in one account (partly) and entire deposits in the undisclosed account were held unexplained. Taxability of those deposits is remanded to the AO for fresh adjudication.
ITAT upholds validity of reopening under s.147 of the Income-tax Act, finding that the AO had prima facie material (undisclosed bank account and substantial unexplained deposits during demonetisation) to infer escapement of income; CIT(A)'s detailed reasons were not controverted by the assessee and sanction under s.151 was effectively accorded. Grounds challenging jurisdictional reopening are dismissed. Reassessment was within the four-year period, so proviso to s.147 is inapplicable. Pursuant to the Explanation to s.147, AO possessed authority to examine and assess deposits beyond the original reasons; deposits in one account (partly) and entire deposits in the undisclosed account were held unexplained. Taxability of those deposits is remanded to the AO for fresh adjudication.
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