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...
Telescoping was applied to undisclosed on-money receipts against cash deposits made during demonetisation, but only 50% relief was granted because no corresponding physical cash was found and the assessee could not fully explain that aspect. The surviving addition was held not chargeable under section 115BBE for the year in question, and had to be taxed under the normal provisions. Receipts described as advances from customers and a loan receipt were treated as business turnover already covered by the telescoping of on-money and were deleted as separate section 68 additions. An addition relating to a creditor was also deleted because the assessee had discharged the initial onus with documents and the creditor had been examined without adverse findings.
Telescoping was applied to undisclosed on-money receipts against cash deposits made during demonetisation, but only 50% relief was granted because no corresponding physical cash was found and the assessee could not fully explain that aspect. The surviving addition was held not chargeable under section 115BBE for the year in question, and had to be taxed under the normal provisions. Receipts described as advances from customers and a loan receipt were treated as business turnover already covered by the telescoping of on-money and were deleted as separate section 68 additions. An addition relating to a creditor was also deleted because the assessee had discharged the initial onus with documents and the creditor had been examined without adverse findings.
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