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...
Revision u/s 263 - LTCG on sale of properties - property had been sold in piecemeal in 14 transactions - stock-in-trade or capital asset - Whether to accept the transactions as being taxable under the Long Term Capital Gain or to reject them and tax them under the head income from business would have been duly considered by the AO at the time of assessment proceedings and the conclusion arrived at by the AO was definitely one of the plausible views - Revision order quashed - AT
Revision u/s 263 - LTCG on sale of properties - property had been sold in piecemeal in 14 transactions - stock-in-trade or capital asset - Whether to accept the transactions as being taxable under the Long Term Capital Gain or to reject them and tax them under the head income from business would have been duly considered by the AO at the time of assessment proceedings and the conclusion arrived at by the AO was definitely one of the plausible views - Revision order quashed - AT
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