Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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Dealing-error losses incurred by a share broker in client transactions are described as allowable where reassessment proceedings examined and accepted their genuineness, with no factual or legal defect identified in the appellate findings. The text also treats losses on proprietary derivative transactions as realised business losses where contract notes, transaction-wise details and contemporaneous records establish that positions were squared off during the relevant year. A corrected factual explanation, supported by evidence, prevails over an initial statement that the loss arose from an open position; compulsory cash settlement supports treatment as realised rather than notional loss.
Dealing-error losses incurred by a share broker in client transactions are described as allowable where reassessment proceedings examined and accepted their genuineness, with no factual or legal defect identified in the appellate findings. The text also treats losses on proprietary derivative transactions as realised business losses where contract notes, transaction-wise details and contemporaneous records establish that positions were squared off during the relevant year. A corrected factual explanation, supported by evidence, prevails over an initial statement that the loss arose from an open position; compulsory cash settlement supports treatment as realised rather than notional loss.
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