Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Section 50B prescribes a self-contained method for computing capital gains on a slump sale, including fair market value and net worth under Rule 11UAE. Where no defect in the valuation methodology or non-compliance with Rule 11UAE is identified, the Assessing Officer cannot substitute a different valuation; deletion of the resulting capital-gains addition was confirmed. A capital-gains addition made without a proper show-cause notice also breached CBDT Instruction No. 20/2015 and was independently unsustainable. The Revenue's appeal was dismissed.
Section 50B prescribes a self-contained method for computing capital gains on a slump sale, including fair market value and net worth under Rule 11UAE. Where no defect in the valuation methodology or non-compliance with Rule 11UAE is identified, the Assessing Officer cannot substitute a different valuation; deletion of the resulting capital-gains addition was confirmed. A capital-gains addition made without a proper show-cause notice also breached CBDT Instruction No. 20/2015 and was independently unsustainable. The Revenue's appeal was dismissed.
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