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 held that the search assessment regime under section 153C is triggered by initiation of search in the case of the searched person, not by the later notice to the other person; because the search and handover of seized material occurred before 01/04/2021, the pre-amended law applied and the notice was valid. On merits, the addition based solely on seized pen drive data and Excel printouts failed because the electronic record was inadmissible for lack of valid section 65B compliance and no independent corroboration existed. The separate addition based on an unsigned third-party voucher was also deleted for want of supporting evidence and for internal inconsistency in the assessment order.
ITAT held that the search assessment regime under section 153C is triggered by initiation of search in the case of the searched person, not by the later notice to the other person; because the search and handover of seized material occurred before 01/04/2021, the pre-amended law applied and the notice was valid. On merits, the addition based solely on seized pen drive data and Excel printouts failed because the electronic record was inadmissible for lack of valid section 65B compliance and no independent corroboration existed. The separate addition based on an unsigned third-party voucher was also deleted for want of supporting evidence and for internal inconsistency in the assessment order.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
