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...
Project-completion accounting, when consistently followed by a real estate developer, is a recognised method and cannot be rejected merely because substantial sale proceeds were received or the Assessing Officer preferred a different revenue-recognition method. Rejection under section 145 was unsustainable because no specific defect showed that the accounts were unreliable, while estimated profit was applied to recorded receipts without an independent basis. Differing flat agreement values also did not establish undisclosed consideration without cogent evidence of actual on-money receipts. Payments for extra work under separate agreements could not be attributed to the developer solely through a director's connection. The book rejection and additions were deleted.
Project-completion accounting, when consistently followed by a real estate developer, is a recognised method and cannot be rejected merely because substantial sale proceeds were received or the Assessing Officer preferred a different revenue-recognition method. Rejection under section 145 was unsustainable because no specific defect showed that the accounts were unreliable, while estimated profit was applied to recorded receipts without an independent basis. Differing flat agreement values also did not establish undisclosed consideration without cogent evidence of actual on-money receipts. Payments for extra work under separate agreements could not be attributed to the developer solely through a director's connection. The book rejection and additions were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
