Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Whether unexplained cash deposits could be bifurcated and subjected to best judgment addition under section 144: Tribunal found bifurcation unjustified because the assessee's sole source of deposits was business receipts from trading in cement and iron-highly competitive commodities-so there was no rational basis for segregating half the deposits as unexplained; consequence: separate addition of unexplained cash deposits set aside. Appropriate profit rate to estimate business income: applying commercial realities and comparable profit standards, Tribunal directed AO to adopt a 6% profit rate on entire receipts and recompute income; appeal partly allowed. - ITAT
Whether unexplained cash deposits could be bifurcated and subjected to best judgment addition under section 144: Tribunal found bifurcation unjustified because the assessee's sole source of deposits was business receipts from trading in cement and iron-highly competitive commodities-so there was no rational basis for segregating half the deposits as unexplained; consequence: separate addition of unexplained cash deposits set aside. Appropriate profit rate to estimate business income: applying commercial realities and comparable profit standards, Tribunal directed AO to adopt a 6% profit rate on entire receipts and recompute income; appeal partly allowed. - ITAT
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