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...
Reopening of assessment was challenged on the ground that the assessing officer had accepted the assessee's explanation regarding the source of investment in property. The tribunal relied on precedent to conclude that once the AO accepted the explanation recorded in reasons, the AO lacked basis to make an independent addition in respect of that subject-matter. Consequently, the addition made in the assessment was deleted and the assessment adjustment was set aside in favour of the assessee.
Reopening of assessment was challenged on the ground that the assessing officer had accepted the assessee's explanation regarding the source of investment in property. The tribunal relied on precedent to conclude that once the AO accepted the explanation recorded in reasons, the AO lacked basis to make an independent addition in respect of that subject-matter. Consequently, the addition made in the assessment was deleted and the assessment adjustment was set aside in favour of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
