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...
Disallowance of construction cost for capital gains was overturned where the assessee produced the contractor's confirmation, a cost breakup, identity documents and an income-tax return evidencing the contractor's involvement; the AO had not doubted the work but made an ad hoc 50% reduction without identifying any cogent defect in the contractor's confirmation or the breakup. The Tribunal held that the contractor's confirmation and supporting particulars carried evidentiary weight and could not be summarily disregarded, and accordingly deleted the addition arising from the 50% disallowance.
Disallowance of construction cost for capital gains was overturned where the assessee produced the contractor's confirmation, a cost breakup, identity documents and an income-tax return evidencing the contractor's involvement; the AO had not doubted the work but made an ad hoc 50% reduction without identifying any cogent defect in the contractor's confirmation or the breakup. The Tribunal held that the contractor's confirmation and supporting particulars carried evidentiary weight and could not be summarily disregarded, and accordingly deleted the addition arising from the 50% disallowance.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
