Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Unexplained cash deposits during demonetisation: the Tribunal held that cash deposited in the bank derived from prior household savings and recorded in the assessee's books, and once receipts are reflected in books and accepted by the assessing officer, the onus to further explain does not sustain an addition under section 69A; consequence - addition under s.69A deleted. Double taxation and prior acceptance of receipts: re-taxing the same receipts under s.69A would amount to double taxation, therefore such duplicate addition is impermissible - consequence - deleted. Evidentiary deficiencies: poor documentary compliance justified partial relief; consequence - a compensatory addition of 10% of Rs.29,60,000 (Rs.2,96,000) sustained. Section 115BBE: deposits held to arise from business and thus not liable to flat rate under s.115BBE; consequence - tax the Rs.2,96,000 at normal rates by the AO. - ITAT
Unexplained cash deposits during demonetisation: the Tribunal held that cash deposited in the bank derived from prior household savings and recorded in the assessee's books, and once receipts are reflected in books and accepted by the assessing officer, the onus to further explain does not sustain an addition under section 69A; consequence - addition under s.69A deleted. Double taxation and prior acceptance of receipts: re-taxing the same receipts under s.69A would amount to double taxation, therefore such duplicate addition is impermissible - consequence - deleted. Evidentiary deficiencies: poor documentary compliance justified partial relief; consequence - a compensatory addition of 10% of Rs.29,60,000 (Rs.2,96,000) sustained. Section 115BBE: deposits held to arise from business and thus not liable to flat rate under s.115BBE; consequence - tax the Rs.2,96,000 at normal rates by the AO. - ITAT
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