Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Treatment of a negative cash balance as income from unexplained sources was upheld because the taxpayer failed to prove that alleged cash gifts had a verifiable donor source. The court applied the principle that cash gifts require independent evidence of the donor's capacity and source of funds; self signed receipts and a post hoc declaration were insufficient. Inconsistent statements about the donor and absence of the donor's tax filings or other corroboration undermined credibility, leading to rejection of the gift claim and endorsement of the unexplained cash balance being taxed as income.
Treatment of a negative cash balance as income from unexplained sources was upheld because the taxpayer failed to prove that alleged cash gifts had a verifiable donor source. The court applied the principle that cash gifts require independent evidence of the donor's capacity and source of funds; self signed receipts and a post hoc declaration were insufficient. Inconsistent statements about the donor and absence of the donor's tax filings or other corroboration undermined credibility, leading to rejection of the gift claim and endorsement of the unexplained cash balance being taxed as income.
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