Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
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In the case before ITAT Delhi, the issue was the admissibility of additional evidence related to Long Term Capital Gains (LTCG) and deduction under section 54F. The assessee submitted evidence to prove that the agricultural land sold was not a capital asset and that the sale consideration was reinvested as per section 54F. The Tribunal held that the additional evidence should be considered under Rule 46A, despite not being presented before the Assessing Officer (AO). The CIT(A) erred in not admitting the evidence, citing a Supreme Court decision. The Tribunal emphasized that the CIT(A) has powers equal to the AO and can accept additional claims without the need for the assessee to revise the return. The appeal was allowed for statistical purposes.
In the case before ITAT Delhi, the issue was the admissibility of additional evidence related to Long Term Capital Gains (LTCG) and deduction under section 54F. The assessee submitted evidence to prove that the agricultural land sold was not a capital asset and that the sale consideration was reinvested as per section 54F. The Tribunal held that the additional evidence should be considered under Rule 46A, despite not being presented before the Assessing Officer (AO). The CIT(A) erred in not admitting the evidence, citing a Supreme Court decision. The Tribunal emphasized that the CIT(A) has powers equal to the AO and can accept additional claims without the need for the assessee to revise the return. The appeal was allowed for statistical purposes.
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