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...
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Whether incriminating material seized in search sustains additions under section 153A - tribunal, following Benefit Tradelink, finds the issue against the assessee and dismisses the ground challenging additions. Addition as income under section 56(2)(vi) for amounts received as student fees - since receipts were offered to tax before the Settlement Commission and constituted student fees, section 56(2)(vi) is not attracted and no addition is warranted. Unexplained investment in property - pro rata contribution recomputed and limited to Rs.1,42,000, ground partly allowed. Purchase of specified land - amounts already offered before the Settlement Commission; no further addition. Stamp duty/registration expenses paid by relatives and not offered earlier - Revenue free to tax those amounts. - ITAT
Whether incriminating material seized in search sustains additions under section 153A - tribunal, following Benefit Tradelink, finds the issue against the assessee and dismisses the ground challenging additions. Addition as income under section 56(2)(vi) for amounts received as student fees - since receipts were offered to tax before the Settlement Commission and constituted student fees, section 56(2)(vi) is not attracted and no addition is warranted. Unexplained investment in property - pro rata contribution recomputed and limited to Rs.1,42,000, ground partly allowed. Purchase of specified land - amounts already offered before the Settlement Commission; no further addition. Stamp duty/registration expenses paid by relatives and not offered earlier - Revenue free to tax those amounts. - ITAT
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