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...
The ITAT deleted the addition for alleged misclassification of interest income after finding that the assessee had disclosed total receipts, including foodgrain business receipts and Sharafi interest receipts, in the return computed under section 44AD. The Tribunal held that the amount treated as escaped income had already formed part of the disclosed aggregate turnover, so a separate addition would amount to duplication. It also noted that details such as the profit and loss account of the Sharafi business had been furnished before the AO, and that the books of account had not been rejected. On that basis, the AO's treatment was held unjustified and the addition was deleted.
The ITAT deleted the addition for alleged misclassification of interest income after finding that the assessee had disclosed total receipts, including foodgrain business receipts and Sharafi interest receipts, in the return computed under section 44AD. The Tribunal held that the amount treated as escaped income had already formed part of the disclosed aggregate turnover, so a separate addition would amount to duplication. It also noted that details such as the profit and loss account of the Sharafi business had been furnished before the AO, and that the books of account had not been rejected. On that basis, the AO's treatment was held unjustified and the addition was deleted.
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