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...
Angadia cash-transit entries representing clients' funds do not constitute the operator's unexplained money where the operator acts only as a facilitator and no evidence establishes ownership or accrual of the principal. Only the embedded profit or commission is taxable, not gross cash-transit receipts. Commission embedded in unaccounted turnover was estimated at 0.30 per cent after credit for commission already assessed, reflecting the low-margin nature of the business, operating margins, scale of operations and comparable Angadia decisions. Such commission is taxable at normal rates rather than under section 115BBE, and additions for gross principal cash transactions were deleted.
Angadia cash-transit entries representing clients' funds do not constitute the operator's unexplained money where the operator acts only as a facilitator and no evidence establishes ownership or accrual of the principal. Only the embedded profit or commission is taxable, not gross cash-transit receipts. Commission embedded in unaccounted turnover was estimated at 0.30 per cent after credit for commission already assessed, reflecting the low-margin nature of the business, operating margins, scale of operations and comparable Angadia decisions. Such commission is taxable at normal rates rather than under section 115BBE, and additions for gross principal cash transactions were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
