Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
ITAT held that cash deposits supported by recorded cash sales could not be treated as unexplained cash credit where the assessee produced purchase and sales registers, no specific discrepancy was found in sales, purchases or cash book, and the books were not rejected; absence of a stock register alone was insufficient, so the section 68 addition on that account was deleted. For the claimed capital introduction based on an alleged gift, the appellate relief was unsustainable because the new material was not properly tested through due process, including verification of the donor's identity, genuineness and creditworthiness; that issue was set aside and remanded to the AO for de novo adjudication.
ITAT held that cash deposits supported by recorded cash sales could not be treated as unexplained cash credit where the assessee produced purchase and sales registers, no specific discrepancy was found in sales, purchases or cash book, and the books were not rejected; absence of a stock register alone was insufficient, so the section 68 addition on that account was deleted. For the claimed capital introduction based on an alleged gift, the appellate relief was unsustainable because the new material was not properly tested through due process, including verification of the donor's identity, genuineness and creditworthiness; that issue was set aside and remanded to the AO for de novo adjudication.
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