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...
Presumptive taxation: where an assessee opts to declare income under the presumptive scheme and offers income accordingly, separate additions for unexplained cash bank deposits cannot be sustained; the tribunal relied on precedent holding that opting into the presumptive regime removes the obligation to explain each cash entry, and directed deletion of the addition. The appellate authority allowed the assessee's appeal and set aside the lower appellate order that had limited relief to bank debits, restoring complete relief against the addition by the assessing officer.
Presumptive taxation: where an assessee opts to declare income under the presumptive scheme and offers income accordingly, separate additions for unexplained cash bank deposits cannot be sustained; the tribunal relied on precedent holding that opting into the presumptive regime removes the obligation to explain each cash entry, and directed deletion of the addition. The appellate authority allowed the assessee's appeal and set aside the lower appellate order that had limited relief to bank debits, restoring complete relief against the addition by the assessing officer.
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