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...
Regarding long-term capital gain determination, indexed cost of acquisition claimed by assessee at Rs. 45 lakhs for property valued over Rs. 45 lakhs, evidenced by payment through cheques, held acceptable for indexation benefit computation. Addition of Rs. 33,73,120 towards long-term capital gain directed to be deleted. Concerning denial of benefit of carry forward of capital loss, despite setting off long-term capital gain against long-term capital loss as per DRP direction, assessee held entitled to avail carry forward of remaining long-term capital loss. Assessing Officer directed to verify factually and allow carry forward of long-term capital loss claimed.
Regarding long-term capital gain determination, indexed cost of acquisition claimed by assessee at Rs. 45 lakhs for property valued over Rs. 45 lakhs, evidenced by payment through cheques, held acceptable for indexation benefit computation. Addition of Rs. 33,73,120 towards long-term capital gain directed to be deleted. Concerning denial of benefit of carry forward of capital loss, despite setting off long-term capital gain against long-term capital loss as per DRP direction, assessee held entitled to avail carry forward of remaining long-term capital loss. Assessing Officer directed to verify factually and allow carry forward of long-term capital loss claimed.
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