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...
Addition under section 68 concerning unsecured loans addressed the onus of proof regarding lender identity, creditworthiness and genuineness of transactions; the taxpayer discharged the primary onus by adducing credible evidence and fact-based findings supporting lender identity and creditworthiness, leading to deletion of the addition by the first appellate authority which the appellate body declined to disturb. Reliance on prior judicial precedents supporting the factual conclusions was noted, and the revenues grounds challenging the deletion were dismissed.
Addition under section 68 concerning unsecured loans addressed the onus of proof regarding lender identity, creditworthiness and genuineness of transactions; the taxpayer discharged the primary onus by adducing credible evidence and fact-based findings supporting lender identity and creditworthiness, leading to deletion of the addition by the first appellate authority which the appellate body declined to disturb. Reliance on prior judicial precedents supporting the factual conclusions was noted, and the revenues grounds challenging the deletion were dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
