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...
The ITAT held: Long term capital gain was to be computed allowing deduction for indexed cost of acquisition and exemption u/s 54B. Addition u/s 68 for unexplained investment in immovable property was deleted as assessee furnished sufficient evidence regarding source. Addition u/s 69 for unexplained investment was also deleted as source for purchase of property from sale proceeds was duly explained. Disallowance of sundry creditors was rejected as assessee proved genuineness and creditworthiness of lenders. Order was decided in favour of assessee.
The ITAT held: Long term capital gain was to be computed allowing deduction for indexed cost of acquisition and exemption u/s 54B. Addition u/s 68 for unexplained investment in immovable property was deleted as assessee furnished sufficient evidence regarding source. Addition u/s 69 for unexplained investment was also deleted as source for purchase of property from sale proceeds was duly explained. Disallowance of sundry creditors was rejected as assessee proved genuineness and creditworthiness of lenders. Order was decided in favour of assessee.
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