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...
The ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s deletion of additions made under section 69C arising from a search under section 132, holding that the AO's findings were inconclusive and uncorroborated. The Tribunal found that alleged payments for transfers/postings were supported only by material seized from third parties and digital evidence, with no direct nexus established to the assessee and with denials by the assessee; requests for cross-examination were refused below. In these circumstances, and having regard to coordinate bench reasoning on identical facts, the ITAT concluded the additions could not be sustained and affirmed deletion by the CIT(A).
The ITAT dismissed the Revenue's appeal and upheld the CIT(A)'s deletion of additions made under section 69C arising from a search under section 132, holding that the AO's findings were inconclusive and uncorroborated. The Tribunal found that alleged payments for transfers/postings were supported only by material seized from third parties and digital evidence, with no direct nexus established to the assessee and with denials by the assessee; requests for cross-examination were refused below. In these circumstances, and having regard to coordinate bench reasoning on identical facts, the ITAT concluded the additions could not be sustained and affirmed deletion by the CIT(A).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
