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...
Addition under ss. 69 and 69C for alleged unexplained investment and expenditure in purchase of immovable property held jointly with the assessee's parent was unsustainable because the assessee established the source of funds as amounts received from the other parent's accumulated salary and pension savings, and the revenue failed to rebut this explanation. The absence of old retirement documents was not treated as fatal given the long lapse of time since retirement and the availability of fund-utilization details for the purchase consideration and incidental expenses. The additions were directed to be deleted and the appeal was allowed - ITAT
Addition under ss. 69 and 69C for alleged unexplained investment and expenditure in purchase of immovable property held jointly with the assessee's parent was unsustainable because the assessee established the source of funds as amounts received from the other parent's accumulated salary and pension savings, and the revenue failed to rebut this explanation. The absence of old retirement documents was not treated as fatal given the long lapse of time since retirement and the availability of fund-utilization details for the purchase consideration and incidental expenses. The additions were directed to be deleted and the appeal was allowed - ITAT
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TaxTMI 
TaxTMI 
of 4918 
