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...
ITAT held that a reassessment addition based on a third-party unsigned excel sheet could not be sustained without correlation to the assessee's transaction and without corroborative evidence. The sheet related to a different project and an earlier period, while the assessee's property purchase was in another project and was shown as paid by cheque. As the Assessing Officer failed to establish any actual cash payment or produce supporting statements, and the developer's affidavit denied receipt of cash, the material was insufficient to prove unexplained investment. The addition was deleted and the assessee's appeal was allowed.
ITAT held that a reassessment addition based on a third-party unsigned excel sheet could not be sustained without correlation to the assessee's transaction and without corroborative evidence. The sheet related to a different project and an earlier period, while the assessee's property purchase was in another project and was shown as paid by cheque. As the Assessing Officer failed to establish any actual cash payment or produce supporting statements, and the developer's affidavit denied receipt of cash, the material was insufficient to prove unexplained investment. The addition was deleted and the assessee's appeal was allowed.
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TaxTMI 
TaxTMI 
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