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...
Dispute concerns revenue recognition where the assessing officer treated finished goods/advances as sales despite the assessee following the project completion method. The tribunal found that the amounts were offered to tax in subsequent assessment years and taxed on profits thereon, making the AO's estimate result in double taxation; accordingly the addition treating such stock/advances as turnover was deleted. Reliance on precedents supporting deletion where income is taxed in later years was noted. Resultantly, all grounds of appeal raising this treatment were allowed and the impugned additions were set aside.
Dispute concerns revenue recognition where the assessing officer treated finished goods/advances as sales despite the assessee following the project completion method. The tribunal found that the amounts were offered to tax in subsequent assessment years and taxed on profits thereon, making the AO's estimate result in double taxation; accordingly the addition treating such stock/advances as turnover was deleted. Reliance on precedents supporting deletion where income is taxed in later years was noted. Resultantly, all grounds of appeal raising this treatment were allowed and the impugned additions were set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
