Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
The Appellate Tribunal considered the validity of reassessment proceedings u/s 147 regarding unexplained investment u/s 69 and whether it is taxable in the current assessment year. Referring to a judgment, it was held that capital gains are taxable in the previous assessment year when the relevant transaction occurred. As the impugned capital gain was not taxable in the current assessment year, the reasons for reassessment were deemed unsustainable. The reassessment proceedings were quashed in favor of the assessee based on the precedent set by the judgment cited. Consequently, the assessee's appeal was allowed.
The Appellate Tribunal considered the validity of reassessment proceedings u/s 147 regarding unexplained investment u/s 69 and whether it is taxable in the current assessment year. Referring to a judgment, it was held that capital gains are taxable in the previous assessment year when the relevant transaction occurred. As the impugned capital gain was not taxable in the current assessment year, the reasons for reassessment were deemed unsustainable. The reassessment proceedings were quashed in favor of the assessee based on the precedent set by the judgment cited. Consequently, the assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.