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...
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The appellant did not acquire a new residential property within the specified time period, failing the mandatory condition for deduction u/s 54. The CIT(A)-NFAC incorrectly invoked the "one year before the transfer" limb, concluding that the assessee is ineligible for deduction. However, the relevant date for computing the limitation u/s 54 in all three eventualities is the payment of consideration and possession of the new property. Judicial precedents support this interpretation. The assessee is entitled to the deduction u/s 54.
The appellant did not acquire a new residential property within the specified time period, failing the mandatory condition for deduction u/s 54. The CIT(A)-NFAC incorrectly invoked the "one year before the transfer" limb, concluding that the assessee is ineligible for deduction. However, the relevant date for computing the limitation u/s 54 in all three eventualities is the payment of consideration and possession of the new property. Judicial precedents support this interpretation. The assessee is entitled to the deduction u/s 54.
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