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...
Whether income could be extrapolated from a list of purported employees found during a survey: the Tribunal held that additions must be confined to incriminating material seized during survey and cannot be extrapolated without independent corroboration; reliance on precedent rejecting extrapolation further supports this reasoning, therefore extrapolation across months was unsustainable and disallowed. Consequence: the addition is restricted to Rs. 2,54,115 as per the seized document, taxed under section 69C read with section 115BBE; appeal partly allowed. - ITAT
Whether income could be extrapolated from a list of purported employees found during a survey: the Tribunal held that additions must be confined to incriminating material seized during survey and cannot be extrapolated without independent corroboration; reliance on precedent rejecting extrapolation further supports this reasoning, therefore extrapolation across months was unsustainable and disallowed. Consequence: the addition is restricted to Rs. 2,54,115 as per the seized document, taxed under section 69C read with section 115BBE; appeal partly allowed. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
