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 held that seized material and search statements did not conclusively establish falsification of entries or bogus purchase invoices, though accounting deficiencies justified rejection of books under s.145. It upheld the CIT(A)'s best judgment assessment under s.144, sustaining estimation of business profits at 10% of turnover, following industry comparables and the Empee Distilleries precedent. ITAT further ruled that, once income is estimated, separate disallowances (including data centre expenses and addition on sale of scrap) and additions under s.68 are impermissible, all deductions being subsumed in the profit estimate. Disallowance of CSR expenditure was also deleted as no deduction had been claimed. The Revenue's appeal was accordingly dismissed.
ITAT held that seized material and search statements did not conclusively establish falsification of entries or bogus purchase invoices, though accounting deficiencies justified rejection of books under s.145. It upheld the CIT(A)'s best judgment assessment under s.144, sustaining estimation of business profits at 10% of turnover, following industry comparables and the Empee Distilleries precedent. ITAT further ruled that, once income is estimated, separate disallowances (including data centre expenses and addition on sale of scrap) and additions under s.68 are impermissible, all deductions being subsumed in the profit estimate. Disallowance of CSR expenditure was also deleted as no deduction had been claimed. The Revenue's appeal was accordingly dismissed.
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