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...
ITAT deleted additions for alleged bogus purchases of capital assets and other purchases because the assessee substantiated genuineness with invoices, transport documents, bank loan agreement, bank statements and an insurance policy issued after physical inspection of the assets. The tribunal held that the assets were financed by the bank and were in existence, which contradicted the allegation of accommodation entries. It also noted that the assessee had not claimed the capital asset purchases as revenue expenditure in the profit and loss account, and the Assessing Officer relied only on unverified information without independent inquiry. On these facts, the purchases were not bogus and the additions were deleted.
ITAT deleted additions for alleged bogus purchases of capital assets and other purchases because the assessee substantiated genuineness with invoices, transport documents, bank loan agreement, bank statements and an insurance policy issued after physical inspection of the assets. The tribunal held that the assets were financed by the bank and were in existence, which contradicted the allegation of accommodation entries. It also noted that the assessee had not claimed the capital asset purchases as revenue expenditure in the profit and loss account, and the Assessing Officer relied only on unverified information without independent inquiry. On these facts, the purchases were not bogus and the additions were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
