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...
The Income Tax Appellate Tribunal (ITAT) upheld the Commissioner of Income Tax (Appeals) [CIT(A)] order allowing deduction u/s 54EC for investments made in Rural Electrification Corporation (REC) bonds prior to the sale of property resulting in long-term capital gains (LTCG). The amendment introducing a cap of Rs. 50 lakhs on the deduction was prospective, effective from April 1, 2015. The assessee's investments in REC bonds made on March 31, 2010, April 8, 2010, and July 21, 2010, predated the amendment, hence the cap did not apply. The ITAT relied on precedents and legislative intent to conclude that the CIT(A) correctly allowed the deduction without the cap for investments made before the amendment's effective date.
The Income Tax Appellate Tribunal (ITAT) upheld the Commissioner of Income Tax (Appeals) [CIT(A)] order allowing deduction u/s 54EC for investments made in Rural Electrification Corporation (REC) bonds prior to the sale of property resulting in long-term capital gains (LTCG). The amendment introducing a cap of Rs. 50 lakhs on the deduction was prospective, effective from April 1, 2015. The assessee's investments in REC bonds made on March 31, 2010, April 8, 2010, and July 21, 2010, predated the amendment, hence the cap did not apply. The ITAT relied on precedents and legislative intent to conclude that the CIT(A) correctly allowed the deduction without the cap for investments made before the amendment's effective date.
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