Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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The Appellate Tribunal addressed the issue of the retrospective or prospective application of amended provisions of Section 50C regarding Capital Gain computation. Citing a case precedent, it was held that the proviso to Section 50C(1) should be considered retrospective from its inception. Consequently, the amendment to Section 50C applies retrospectively, requiring the recomputation of capital gains based on stamp duty value at the agreement date. The decision favored the taxpayer, rejecting the revenue's stance.
The Appellate Tribunal addressed the issue of the retrospective or prospective application of amended provisions of Section 50C regarding Capital Gain computation. Citing a case precedent, it was held that the proviso to Section 50C(1) should be considered retrospective from its inception. Consequently, the amendment to Section 50C applies retrospectively, requiring the recomputation of capital gains based on stamp duty value at the agreement date. The decision favored the taxpayer, rejecting the revenue's stance.
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