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 Appellate Tribunal considered whether the transfer of the right to acquire property should be categorized as a long-term or short-term capital gain. The Tribunal found that the right accrued to the assessee upon issuance of the allotment letter, granting the right to purchase the flat. The holding period was determined to commence from the date of the allotment letter, resulting in the gain being classified as long-term. Additionally, the Tribunal allowed the deduction claim u/s 54F, emphasizing the authority of appellate bodies to entertain such claims. The matter was remitted to the Assessing Officer for verification in accordance with the law.
The Appellate Tribunal considered whether the transfer of the right to acquire property should be categorized as a long-term or short-term capital gain. The Tribunal found that the right accrued to the assessee upon issuance of the allotment letter, granting the right to purchase the flat. The holding period was determined to commence from the date of the allotment letter, resulting in the gain being classified as long-term. Additionally, the Tribunal allowed the deduction claim u/s 54F, emphasizing the authority of appellate bodies to entertain such claims. The matter was remitted to the Assessing Officer for verification in accordance with the law.
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