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...
Whether addition under s.69 for alleged cash "on-money" paid for purchase of a shop could be sustained merely on statements recorded during search and an Excel sheet found in a third party's pen drive. The material on record, including allotment letter and bank statements, showed no evidence of any cash payment in AYs 2017-18 and 2018-19 and indicated that the purchase transaction occurred only in AY 2019-20; hence the s.69 additions for AYs 2017-18 and 2018-19 were deleted. For AY 2019-20, the statements and Excel sheet were held uncorroborated by independent evidence, consistent with co-ordinate bench precedents; hence the s.69 addition was deleted and the appeals were allowed - ITAT
Whether addition under s.69 for alleged cash "on-money" paid for purchase of a shop could be sustained merely on statements recorded during search and an Excel sheet found in a third party's pen drive. The material on record, including allotment letter and bank statements, showed no evidence of any cash payment in AYs 2017-18 and 2018-19 and indicated that the purchase transaction occurred only in AY 2019-20; hence the s.69 additions for AYs 2017-18 and 2018-19 were deleted. For AY 2019-20, the statements and Excel sheet were held uncorroborated by independent evidence, consistent with co-ordinate bench precedents; hence the s.69 addition was deleted and the appeals were allowed - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
