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...
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Addition for revaluation of closing stock was contested on the ground that the assessee had previously provided for diminution in value of old/damaged stock and revalued closing stock for the year with a quantified reduction of Rs. 26,88,599, not the higher figure estimated by the AO; the Tribunal accepted the lower figure. The Tribunal found the valuation procedure-branch head physical verification, Director of Societies supervision, auditor approval-scientific and reasonable and, since audited books were not rejected under Section 145(3), held the AO's addition on stock valuation unjustified.
Addition for revaluation of closing stock was contested on the ground that the assessee had previously provided for diminution in value of old/damaged stock and revalued closing stock for the year with a quantified reduction of Rs. 26,88,599, not the higher figure estimated by the AO; the Tribunal accepted the lower figure. The Tribunal found the valuation procedure-branch head physical verification, Director of Societies supervision, auditor approval-scientific and reasonable and, since audited books were not rejected under Section 145(3), held the AO's addition on stock valuation unjustified.
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