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 search assessment under section 153A, an estimated commission addition was unsustainable because only copies of registered sale deeds were found, and no incriminating material showed brokerage activity or receipt of commission; the Tribunal held the addition was based only on assumption and presumption and affirmed its deletion. A protective addition for alleged cash expenditure also failed because the seized documents were owned up by another person, supported by affidavit, and had already been considered in settlement proceedings; once no further addition was called for on those documents, the protective basis disappeared. The Tribunal dismissed the Revenue's appeal and upheld deletion of both additions.
In search assessment under section 153A, an estimated commission addition was unsustainable because only copies of registered sale deeds were found, and no incriminating material showed brokerage activity or receipt of commission; the Tribunal held the addition was based only on assumption and presumption and affirmed its deletion. A protective addition for alleged cash expenditure also failed because the seized documents were owned up by another person, supported by affidavit, and had already been considered in settlement proceedings; once no further addition was called for on those documents, the protective basis disappeared. The Tribunal dismissed the Revenue's appeal and upheld deletion of both additions.
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TaxTMI 
TaxTMI 
of 4918 
