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...
Capital-gains computation for an unquoted equity-share transfer uses the consideration actually received or accruing from that transfer; a notional value may replace it only under an express statutory fiction. The prescribed fair-market-value substitution did not apply where the declared consideration exceeded fair market value. Demat records and contemporaneous delivery instructions established completion of the earlier transfer, and later settlement of the purchaser's liability could not alter its transfer date or consideration. A subsequent transfer under a different ownership and contractual structure could not substitute its consideration for the earlier transaction, particularly where conditions had not crystallised the final price. The capital-gains addition was therefore deleted.
Capital-gains computation for an unquoted equity-share transfer uses the consideration actually received or accruing from that transfer; a notional value may replace it only under an express statutory fiction. The prescribed fair-market-value substitution did not apply where the declared consideration exceeded fair market value. Demat records and contemporaneous delivery instructions established completion of the earlier transfer, and later settlement of the purchaser's liability could not alter its transfer date or consideration. A subsequent transfer under a different ownership and contractual structure could not substitute its consideration for the earlier transaction, particularly where conditions had not crystallised the final price. The capital-gains addition was therefore deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
