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 dismissed the Revenue's appeal and upheld the deletion of addition u/s 68 r.w.s. 115BBE on cash deposits of specified bank notes during demonetisation. The Tribunal held that the impugned cash deposits represented recorded sales already credited to the Profit & Loss account, duly reflected in audited books and VAT/Sales Tax returns, with no rejection of books or discrepancy in sales, purchases or stock by the AO. Since the sales were accepted as genuine and payments for purchases were routed through banking channels, invoking s.68 would result in impermissible double addition. The order of CIT(A) deleting the addition was affirmed.
ITAT dismissed the Revenue's appeal and upheld the deletion of addition u/s 68 r.w.s. 115BBE on cash deposits of specified bank notes during demonetisation. The Tribunal held that the impugned cash deposits represented recorded sales already credited to the Profit & Loss account, duly reflected in audited books and VAT/Sales Tax returns, with no rejection of books or discrepancy in sales, purchases or stock by the AO. Since the sales were accepted as genuine and payments for purchases were routed through banking channels, invoking s.68 would result in impermissible double addition. The order of CIT(A) deleting the addition was affirmed.
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