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 allowed the appeal of the assessee, deleting the addition made by the AO on account of alleged excess purchases based on differences between VAT returns and books of account. ITAT held that, under the applicable VAT Rules, mandatory reversal of input tax credit on goods returned necessarily causes variations between VAT records and commercial books, without implying inflation of purchases. The assessee's supplier-wise reconciliation was found credible, and no material was brought by the AO to establish bogus or unverifiable purchases. With sales figures matching in both records and the variation being less than one percent of total purchases, ITAT found the disallowance by AO and its confirmation by CIT(A) unjustified.
ITAT allowed the appeal of the assessee, deleting the addition made by the AO on account of alleged excess purchases based on differences between VAT returns and books of account. ITAT held that, under the applicable VAT Rules, mandatory reversal of input tax credit on goods returned necessarily causes variations between VAT records and commercial books, without implying inflation of purchases. The assessee's supplier-wise reconciliation was found credible, and no material was brought by the AO to establish bogus or unverifiable purchases. With sales figures matching in both records and the variation being less than one percent of total purchases, ITAT found the disallowance by AO and its confirmation by CIT(A) unjustified.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
