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...
AT dismissed both appeals and upheld the impugned provisional attachment and adjudication orders under the PBPTA. The Tribunal found the Approving Authority applied independent mind, relied on inquiry materials and notes, and concluded the references and orders were within the one-year limitation under s.26(7). The Appellant failed to discharge the evidential burden to prove legitimate consideration for two properties; cash payments and unexplained bank deposits, absence of corroborative agricultural income and missing ITRs warranted inference of non-agricultural/benami dealings. Alleged procedural flaws were characterized as mere surmises. Consequently, the PAO and consequent adjudication were sustained and both appeals were dismissed.
AT dismissed both appeals and upheld the impugned provisional attachment and adjudication orders under the PBPTA. The Tribunal found the Approving Authority applied independent mind, relied on inquiry materials and notes, and concluded the references and orders were within the one-year limitation under s.26(7). The Appellant failed to discharge the evidential burden to prove legitimate consideration for two properties; cash payments and unexplained bank deposits, absence of corroborative agricultural income and missing ITRs warranted inference of non-agricultural/benami dealings. Alleged procedural flaws were characterized as mere surmises. Consequently, the PAO and consequent adjudication were sustained and both appeals were dismissed.
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