Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Taxpayer sold shops during AY 2017-18 and reported gains as Long Term Capital Gains (LTCG) in tax returns. While AO initially accepted this classification under section 143(3), the characterization was later disputed. ITAT ruled in favor of taxpayer, upholding LTCG treatment based on principle of consistency. Since revenue authorities had previously accepted property as investment and gains as LTCG, and there was no change in nature of property holding during assessment year, gains could not be reclassified as business income. Tribunal emphasized that consistent tax treatment must be maintained when underlying facts remain unchanged. Revenue's appeal dismissed.
Taxpayer sold shops during AY 2017-18 and reported gains as Long Term Capital Gains (LTCG) in tax returns. While AO initially accepted this classification under section 143(3), the characterization was later disputed. ITAT ruled in favor of taxpayer, upholding LTCG treatment based on principle of consistency. Since revenue authorities had previously accepted property as investment and gains as LTCG, and there was no change in nature of property holding during assessment year, gains could not be reclassified as business income. Tribunal emphasized that consistent tax treatment must be maintained when underlying facts remain unchanged. Revenue's appeal dismissed.
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