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...
The ITAT ruled that the transfer of booking rights in a capital asset was completed in AY 2009-10, not AY 2008-09. The agreement to sell was contingent on builder's permission granted in 2008. Therefore, the capital gain addition in AY 2008-09 was deleted, and in AY 2009-10, it was converted from protective to substantive basis. The assessee's grounds were allowed.
The ITAT ruled that the transfer of booking rights in a capital asset was completed in AY 2009-10, not AY 2008-09. The agreement to sell was contingent on builder's permission granted in 2008. Therefore, the capital gain addition in AY 2008-09 was deleted, and in AY 2009-10, it was converted from protective to substantive basis. The assessee's grounds were allowed.
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