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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ITAT ruled in favor of taxpayer regarding treatment of gains from diamond sales. Assessee received rough diamonds as gift from grandfather in AY 1994-95, which were later processed and sold. The Tribunal determined the period of holding should be calculated from gift receipt date, qualifying the assets as long-term capital assets. Despite conflicting CBDT circulars, ITAT held that statutory provisions prevail over administrative circulars. The gains were properly characterized as Long Term Capital Gains (LTCG) u/s 2(42A) of Income Tax Act, rejecting revenue's attempt to treat proceeds as unexplained cash credits u/s 68. The documented chain of possession, processing, and sale established legitimate transaction basis, negating revenue's unexplained credit allegations.
ITAT ruled in favor of taxpayer regarding treatment of gains from diamond sales. Assessee received rough diamonds as gift from grandfather in AY 1994-95, which were later processed and sold. The Tribunal determined the period of holding should be calculated from gift receipt date, qualifying the assets as long-term capital assets. Despite conflicting CBDT circulars, ITAT held that statutory provisions prevail over administrative circulars. The gains were properly characterized as Long Term Capital Gains (LTCG) u/s 2(42A) of Income Tax Act, rejecting revenue's attempt to treat proceeds as unexplained cash credits u/s 68. The documented chain of possession, processing, and sale established legitimate transaction basis, negating revenue's unexplained credit allegations.
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