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...
Addition under s.69 for alleged unexplained investment by a non-resident in its Indian subsidiary was held unsustainable where the investment was recorded in the assessee's books and its nature and source were explained as equity funding received from its foreign parent and onward invested in India, supported by bank statements and audited accounts. Section 69 applies only to investments not recorded in the books and lacking satisfactory explanation; insisting on further source proof despite recorded entries was a misapplication of the provision. The matter was remitted only for limited verification of annual accounts evidencing the parent funding, with a direction to delete the addition if verified, and the appeal was allowed. - ITAT
Addition under s.69 for alleged unexplained investment by a non-resident in its Indian subsidiary was held unsustainable where the investment was recorded in the assessee's books and its nature and source were explained as equity funding received from its foreign parent and onward invested in India, supported by bank statements and audited accounts. Section 69 applies only to investments not recorded in the books and lacking satisfactory explanation; insisting on further source proof despite recorded entries was a misapplication of the provision. The matter was remitted only for limited verification of annual accounts evidencing the parent funding, with a direction to delete the addition if verified, and the appeal was allowed. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
