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...
Whether additions for alleged contrived/fictitious NMCE commodity transactions were sustainable - held that the assessee had declared profits and furnished complete corroborative records (contract notes, broker ledgers, confirmations, bank statements, books) which matched NMCE data obtained u/s 133(6); AO did not identify any discrepancy nor produce independent evidence of fabrication, relying instead on general investigation inputs and selectively deeming parts of the same transactions non-genuine; conclusion: additions lacked factual and legal basis and were deleted. - ITAT
Whether additions for alleged contrived/fictitious NMCE commodity transactions were sustainable - held that the assessee had declared profits and furnished complete corroborative records (contract notes, broker ledgers, confirmations, bank statements, books) which matched NMCE data obtained u/s 133(6); AO did not identify any discrepancy nor produce independent evidence of fabrication, relying instead on general investigation inputs and selectively deeming parts of the same transactions non-genuine; conclusion: additions lacked factual and legal basis and were deleted. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
