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 held that the assessee, though required under Sec. 44AA read with Rule 6F to maintain books and have them audited, established reasonable cause for non-maintenance in the year in question; there was no material showing deliberate, contumacious or dishonest conduct. Consequently, as a one-time measure the penalty under Sec. 271A was deleted and consequential relief granted, subject to the assessee's future compliance with Sec. 44AA. ITAT further held that once non-maintenance under Sec. 271A is accepted, levy of penalty under Sec. 271B (audit default) does not arise and the Sec. 271B penalty was also deleted.
ITAT held that the assessee, though required under Sec. 44AA read with Rule 6F to maintain books and have them audited, established reasonable cause for non-maintenance in the year in question; there was no material showing deliberate, contumacious or dishonest conduct. Consequently, as a one-time measure the penalty under Sec. 271A was deleted and consequential relief granted, subject to the assessee's future compliance with Sec. 44AA. ITAT further held that once non-maintenance under Sec. 271A is accepted, levy of penalty under Sec. 271B (audit default) does not arise and the Sec. 271B penalty was also deleted.
Note: It is a system-generated summary and is for quick reference only.
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