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...
In retail liquor business out-of-books transactions, only the profit element embedded in the unaccounted activity was held taxable, not the gross purchases or duplicated sales stream. The Tribunal found a close nexus between unaccounted purchases, unaccounted sales and cash collections, and restricted the addition to 3% of the relevant unaccounted transactions while deleting the separate substantive and protective additions based on gross purchases and related advances. It further held that cash already deposited in regular bank accounts could not again be treated as unaccounted sales, so the balance alone was subject to 3% estimation. Cash found at the premises was also deleted where the cash book explained availability and telescoping of estimated income was accepted.
In retail liquor business out-of-books transactions, only the profit element embedded in the unaccounted activity was held taxable, not the gross purchases or duplicated sales stream. The Tribunal found a close nexus between unaccounted purchases, unaccounted sales and cash collections, and restricted the addition to 3% of the relevant unaccounted transactions while deleting the separate substantive and protective additions based on gross purchases and related advances. It further held that cash already deposited in regular bank accounts could not again be treated as unaccounted sales, so the balance alone was subject to 3% estimation. Cash found at the premises was also deleted where the cash book explained availability and telescoping of estimated income was accepted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
