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...
The tribunal affirmed that cash deposits in the assessee's proprietorship bank accounts during the demonetisation period were treated as unexplained income where the assessee failed to respond to statutory notices or furnish any explanation or documents; on the basis of bank data the deposits were attributed to the assessee and taxed accordingly. Separately, the claimed current-year loss set off was disallowed because the assessee did not produce supporting details before the tax authorities or on appeal, leaving the claim unsubstantiated. All grounds of appeal were dismissed for lack of material and failure to furnish explanations or appear.
The tribunal affirmed that cash deposits in the assessee's proprietorship bank accounts during the demonetisation period were treated as unexplained income where the assessee failed to respond to statutory notices or furnish any explanation or documents; on the basis of bank data the deposits were attributed to the assessee and taxed accordingly. Separately, the claimed current-year loss set off was disallowed because the assessee did not produce supporting details before the tax authorities or on appeal, leaving the claim unsubstantiated. All grounds of appeal were dismissed for lack of material and failure to furnish explanations or appear.
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