Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
The ITAT Visakhapatnam dealt with a revision u/s 263 regarding the treatment of a residential property sale as short-term or long-term capital asset. The dispute centered on the appropriation between land and building for capital gains computation under a Joint Development Agreement (JDA). The CIT considered the asset as short-term, disallowing deduction u/s 54EC. The ITAT held that the property was incomplete until possession in Feb 2011, emphasizing the necessity of owning both land and building components in such transactions. It highlighted the importance of bifurcating undivided share of land and built-up area for capital gains computation. The ITAT stressed the need for appropriate documentation to claim indexed cost of improvement and discussed the method of appropriating sale consideration for land and building under section 50C. The ITAT concluded that the CIT erred in not considering the appropriation between land and building, directing the AO to re-examine the issue.
The ITAT Visakhapatnam dealt with a revision u/s 263 regarding the treatment of a residential property sale as short-term or long-term capital asset. The dispute centered on the appropriation between land and building for capital gains computation under a Joint Development Agreement (JDA). The CIT considered the asset as short-term, disallowing deduction u/s 54EC. The ITAT held that the property was incomplete until possession in Feb 2011, emphasizing the necessity of owning both land and building components in such transactions. It highlighted the importance of bifurcating undivided share of land and built-up area for capital gains computation. The ITAT stressed the need for appropriate documentation to claim indexed cost of improvement and discussed the method of appropriating sale consideration for land and building under section 50C. The ITAT concluded that the CIT erred in not considering the appropriation between land and building, directing the AO to re-examine the issue.
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