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 affirmed the assessment: the AO's computation of business income at 8% of turnover under section 44AD was sustained, with CIT(A)'s concurrence upheld as a correct finding. Separately, additions relating to acquisition of an immovable asset were also upheld because the assessee failed to discharge the initial onus to establish receipts from relatives-no satisfactory identity, PAN/return evidence, bank statements evidencing receipt/debit, confirmation, repayment records or proof of creditworthiness were furnished. Consequently, the unexplained investment was disallowed and the assessee's appeal was dismissed in its entirety.
ITAT affirmed the assessment: the AO's computation of business income at 8% of turnover under section 44AD was sustained, with CIT(A)'s concurrence upheld as a correct finding. Separately, additions relating to acquisition of an immovable asset were also upheld because the assessee failed to discharge the initial onus to establish receipts from relatives-no satisfactory identity, PAN/return evidence, bank statements evidencing receipt/debit, confirmation, repayment records or proof of creditworthiness were furnished. Consequently, the unexplained investment was disallowed and the assessee's appeal was dismissed in its entirety.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
