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...
Cash advances treated as receipts: Held that cash receipts were advances and under the assessee's established project-completion accounting could not be taxed in the relevant AY but only on project completion; appeal allowed on this issue. Unexplained purchase payments: Addition deleted because corresponding additions in purchasers' hands were removed and statements relied upon were not furnished, vitiating the addition; upheld deletion. Interest disallowance: Deleted since own capital exceeded interest-free advances, permitting presumption advances made from own funds; disallowance overturned. Deemed rent under s.22: sustained. Reassessment valid. TDS non-deduction remitted to AO for verification. Section 68 additions on opening balances deleted. - ITAT
Cash advances treated as receipts: Held that cash receipts were advances and under the assessee's established project-completion accounting could not be taxed in the relevant AY but only on project completion; appeal allowed on this issue. Unexplained purchase payments: Addition deleted because corresponding additions in purchasers' hands were removed and statements relied upon were not furnished, vitiating the addition; upheld deletion. Interest disallowance: Deleted since own capital exceeded interest-free advances, permitting presumption advances made from own funds; disallowance overturned. Deemed rent under s.22: sustained. Reassessment valid. TDS non-deduction remitted to AO for verification. Section 68 additions on opening balances deleted. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
