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...
Penalty under s.270A for "underreporting of income" was challenged on the ground that the assessed addition was made on an estimated basis by lump-sum disallowance of expenses. The Tribunal held that estimated additions are excluded under s.270A(6) only where the accounts are found correct and complete but income cannot be properly deduced from the method employed; here the AO recorded that the books were not correct and complete due to discrepancies and unsupported vouchers, which remained unrebutted, hence penalty was sustainable. Penalty on disallowance under s.40(a)(ia) for TDS default was also upheld as no contrary submissions were made; appeal was dismissed. - ITAT
Penalty under s.270A for "underreporting of income" was challenged on the ground that the assessed addition was made on an estimated basis by lump-sum disallowance of expenses. The Tribunal held that estimated additions are excluded under s.270A(6) only where the accounts are found correct and complete but income cannot be properly deduced from the method employed; here the AO recorded that the books were not correct and complete due to discrepancies and unsupported vouchers, which remained unrebutted, hence penalty was sustainable. Penalty on disallowance under s.40(a)(ia) for TDS default was also upheld as no contrary submissions were made; appeal was dismissed. - ITAT
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