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...
ITAT held that when computing capital gains for inherited/gifted property acquired pre-1981, the "first year asset held" refers to original ownership by previous owner, not date of gift transfer. Assessee correctly computed indexed cost of acquisition from April 2001 base date. Regarding property valuation, comparative sale instances must consider full ownership rights - 25% undivided share properties require upward adjustment. AO's determination of indexed acquisition cost was reasonable after examining documentation and explanations. The assessment order represented a plausible interpretation that was neither erroneous nor prejudicial to Revenue's interests. PCIT's revision under s.263 was unsustainable. Assessee's appeal allowed.
ITAT held that when computing capital gains for inherited/gifted property acquired pre-1981, the "first year asset held" refers to original ownership by previous owner, not date of gift transfer. Assessee correctly computed indexed cost of acquisition from April 2001 base date. Regarding property valuation, comparative sale instances must consider full ownership rights - 25% undivided share properties require upward adjustment. AO's determination of indexed acquisition cost was reasonable after examining documentation and explanations. The assessment order represented a plausible interpretation that was neither erroneous nor prejudicial to Revenue's interests. PCIT's revision under s.263 was unsustainable. Assessee's appeal allowed.
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