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...
Disallowance of set off of Loss - sale of equity shares (STT) - short-term capital gains (STCG) on sale of derivatives and short-term capital loss (STCL) - The Tribunal examined various judicial pronouncements and held that under section 70(2) of the Act, STCL arising from any asset can be set off against STCG arising from any other asset under a similar computation, regardless of the differential tax rates. It emphasized that the computation in both cases is made under the same provisions, allowing for such set-off. Consequently, the Tribunal allowed the appeal of the assessee, affirming their right to set off STCL against STCG.
Disallowance of set off of Loss - sale of equity shares (STT) - short-term capital gains (STCG) on sale of derivatives and short-term capital loss (STCL) - The Tribunal examined various judicial pronouncements and held that under section 70(2) of the Act, STCL arising from any asset can be set off against STCG arising from any other asset under a similar computation, regardless of the differential tax rates. It emphasized that the computation in both cases is made under the same provisions, allowing for such set-off. Consequently, the Tribunal allowed the appeal of the assessee, affirming their right to set off STCL against STCG.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
