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...
Key issues: 1) The treatment of long-term capital gain on inherited/gifted jewelry as short-term capital gain, where the assessee's claim of the jewelry being 30-40 years old was accepted based on valuation report, wife's statement, and jeweler's statement, allowing benefit u/s 54. 2) The disallowance of exemption u/s 54 for 50% share of the wife in the new house property was incorrect, as the entire investment was made by the assessee, and the full value was reflected in Form 26AS. 3) Based on the above findings, the assessee's appeal was allowed by the Appellate Tribunal.
Key issues: 1) The treatment of long-term capital gain on inherited/gifted jewelry as short-term capital gain, where the assessee's claim of the jewelry being 30-40 years old was accepted based on valuation report, wife's statement, and jeweler's statement, allowing benefit u/s 54. 2) The disallowance of exemption u/s 54 for 50% share of the wife in the new house property was incorrect, as the entire investment was made by the assessee, and the full value was reflected in Form 26AS. 3) Based on the above findings, the assessee's appeal was allowed by the Appellate Tribunal.
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