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...
The ITAT set aside the CIT(A)'s order concerning STCG on an ancestral property allegedly sold by the assessee with ten co-owners for Rs. 9.08 crores. The Tribunal remanded the case to the JAO to determine whether the assessee actually transferred any immovable property in AY 2016-17. If no transfer occurred, no capital gain would be taxable; if a transfer is confirmed, capital gains should be assessed according to law. Similarly, the penalties under s.271(1)(c) for concealment of income and s.271F for non-filing of returns were set aside, with instructions that penalties may only be imposed after the JAO completes the reassessment and establishes taxable income exceeding the threshold limit.
The ITAT set aside the CIT(A)'s order concerning STCG on an ancestral property allegedly sold by the assessee with ten co-owners for Rs. 9.08 crores. The Tribunal remanded the case to the JAO to determine whether the assessee actually transferred any immovable property in AY 2016-17. If no transfer occurred, no capital gain would be taxable; if a transfer is confirmed, capital gains should be assessed according to law. Similarly, the penalties under s.271(1)(c) for concealment of income and s.271F for non-filing of returns were set aside, with instructions that penalties may only be imposed after the JAO completes the reassessment and establishes taxable income exceeding the threshold limit.
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TaxTMI 
TaxTMI 
of 4918 
