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...
Section 56(2)(x) deals with the addition of the difference between the fair market value of a property and the consideration paid, to the income of the recipient. The key points are: When the consideration is fixed on the agreement date, and registration occurs later, the stamp duty value on the agreement date is relevant if payment is made through banking channels by that date. The allotment letter from the builder, containing agreed terms and payment schedule, qualifies as an agreement under this provision. If the payment made by the agreed date exceeds the stamp duty value on that date, no addition u/s 56(2)(x) can be made. The Appellate Tribunal dismissed the Revenue's appeal on these grounds.
Section 56(2)(x) deals with the addition of the difference between the fair market value of a property and the consideration paid, to the income of the recipient. The key points are: When the consideration is fixed on the agreement date, and registration occurs later, the stamp duty value on the agreement date is relevant if payment is made through banking channels by that date. The allotment letter from the builder, containing agreed terms and payment schedule, qualifies as an agreement under this provision. If the payment made by the agreed date exceeds the stamp duty value on that date, no addition u/s 56(2)(x) can be made. The Appellate Tribunal dismissed the Revenue's appeal on these grounds.
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