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 allowed the assessee's appeal and deleted the addition made u/s 68 in respect of an outstanding credit standing in the name of the creditor-company. The Tribunal held that a clerical variation in spelling of the creditor's name in the ledger could not override unimpeached documentary evidence, including PAN, ROC records, audited financials, confirmations and past ITAT orders, which conclusively established the creditor's identity and existence. The genuineness of the transaction and creditworthiness were accepted on the basis of a complete, unrebutted banking trail showing receipt and subsequent repayment through the same account. Non-materialisation of the underlying commercial transaction and non-appearance to summons were held legally inconsequential.
ITAT allowed the assessee's appeal and deleted the addition made u/s 68 in respect of an outstanding credit standing in the name of the creditor-company. The Tribunal held that a clerical variation in spelling of the creditor's name in the ledger could not override unimpeached documentary evidence, including PAN, ROC records, audited financials, confirmations and past ITAT orders, which conclusively established the creditor's identity and existence. The genuineness of the transaction and creditworthiness were accepted on the basis of a complete, unrebutted banking trail showing receipt and subsequent repayment through the same account. Non-materialisation of the underlying commercial transaction and non-appearance to summons were held legally inconsequential.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
