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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Determination of long term capital gain u/s 50C - The Tribunal observed that the part payment of consideration was received by the assessee prior to the execution of the agreement to sale. Furthermore, the sale consideration declared by the assessee was significantly higher than the prevailing jantri rate at the time of the agreement. Therefore, the Tribunal held that the assessee was entitled to the benefit of the first and second provisos to Section 50C.
Determination of long term capital gain u/s 50C - The Tribunal observed that the part payment of consideration was received by the assessee prior to the execution of the agreement to sale. Furthermore, the sale consideration declared by the assessee was significantly higher than the prevailing jantri rate at the time of the agreement. Therefore, the Tribunal held that the assessee was entitled to the benefit of the first and second provisos to Section 50C.
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