Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
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Reopening of assessment u/s 147 - initiating notice u/s 148A(b) - alleged information received from DDIT (Inv.), Mumbai that the petitioner opted accommodation entries - The High court noted that the purpose of the inquiry u/s 148A was to determine whether a case for reassessment was made out. It found that the petitioner's admission of the transaction between him and AEPL, not being reflected in the income tax return, constituted a prima facie case for reopening the assessment. - Further, the HC held that the objections raised by the petitioner were more in the nature of explaining why the transaction amount should not be taxable, which would be examined in detail during reassessment proceedings.
Reopening of assessment u/s 147 - initiating notice u/s 148A(b) - alleged information received from DDIT (Inv.), Mumbai that the petitioner opted accommodation entries - The High court noted that the purpose of the inquiry u/s 148A was to determine whether a case for reassessment was made out. It found that the petitioner's admission of the transaction between him and AEPL, not being reflected in the income tax return, constituted a prima facie case for reopening the assessment. - Further, the HC held that the objections raised by the petitioner were more in the nature of explaining why the transaction amount should not be taxable, which would be examined in detail during reassessment proceedings.
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