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 partly allowed the appeal in respect of additions under s.69A r.w.s. and s.115BBE arising from a search at common family premises. The AO's jewellery additions were deleted by the CIT(A) on factual analysis that the jewellery belonged to the family; Revenue did not challenge that finding, rendering it final. As to wrist watches, the AO had attributed all watches to the assessee, but CIT(A) found they were located in a shared residence occupied by multiple family members and, given the family's status and absence of purchase particulars, declined to uphold additions based on contemporary market valuation. The net result is deletion of jewellery additions and rejection of watch additions, with the appeal therefore partly allowed.
ITAT partly allowed the appeal in respect of additions under s.69A r.w.s. and s.115BBE arising from a search at common family premises. The AO's jewellery additions were deleted by the CIT(A) on factual analysis that the jewellery belonged to the family; Revenue did not challenge that finding, rendering it final. As to wrist watches, the AO had attributed all watches to the assessee, but CIT(A) found they were located in a shared residence occupied by multiple family members and, given the family's status and absence of purchase particulars, declined to uphold additions based on contemporary market valuation. The net result is deletion of jewellery additions and rejection of watch additions, with the appeal therefore partly allowed.
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TaxTMI 
TaxTMI 
of 4918 
