Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Execution and registration of the sale deeds transferred ownership rights and completed the transfer of immovable property for capital gains purposes, so short-term capital gains were taxable in AY 2014-15. Delayed receipt of consideration, dishonoured cheques, continued possession, or later disputes did not defer taxability where the registered deeds remained valid and were neither cancelled nor legally rescinded. The Tribunal upheld the addition on timing of transfer, but directed the AO to verify whether the same capital gain had already been assessed in AY 2016-17 and, if so, grant consequential relief to prevent double taxation.
Execution and registration of the sale deeds transferred ownership rights and completed the transfer of immovable property for capital gains purposes, so short-term capital gains were taxable in AY 2014-15. Delayed receipt of consideration, dishonoured cheques, continued possession, or later disputes did not defer taxability where the registered deeds remained valid and were neither cancelled nor legally rescinded. The Tribunal upheld the addition on timing of transfer, but directed the AO to verify whether the same capital gain had already been assessed in AY 2016-17 and, if so, grant consequential relief to prevent double taxation.
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