Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
An allotment letter from a developer is considered an agreement to purchase a property, and payments made through banking channels establish its veracity. The valuation date for determining any deemed gift is the date of the first payment, not the later date of property transfer. CBDT circulars recognize allotment letters as agreements for construction, granting capital gains set-off benefits to purchasers. Applying this analogy, the assessee's allotment letter and cheque payments from June 2010 constitute an agreement, precluding additions u/s 56(2)(vii)(b)(ii) for deemed gifts. The Assessing Officer erred in considering the valuation date as October 2014, and the addition is deleted by the Appellate Tribunal.
An allotment letter from a developer is considered an agreement to purchase a property, and payments made through banking channels establish its veracity. The valuation date for determining any deemed gift is the date of the first payment, not the later date of property transfer. CBDT circulars recognize allotment letters as agreements for construction, granting capital gains set-off benefits to purchasers. Applying this analogy, the assessee's allotment letter and cheque payments from June 2010 constitute an agreement, precluding additions u/s 56(2)(vii)(b)(ii) for deemed gifts. The Assessing Officer erred in considering the valuation date as October 2014, and the addition is deleted by the Appellate Tribunal.
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TaxTMI 
TaxTMI 
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