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 held that the appellant's surrender of tenancy rights constituted a transfer of capital asset under section 2(47). The Tribunal determined that the tenancy right was acquired in 1954 through payment of a non-refundable security deposit of Rs. 1,080, which represented the cost of acquisition under section 55(2)(a)(i). Since the asset was acquired before April 1, 2001, the appellant was entitled to adopt either the fair market value as on that date or the actual cost as the acquisition cost, with indexation benefits under section 48. Based on the valuation certified by a registered government valuer, the transaction resulted in a net capital loss. The ITAT deleted the addition made by the AO, allowing the appellant's grounds of appeal.
The ITAT held that the appellant's surrender of tenancy rights constituted a transfer of capital asset under section 2(47). The Tribunal determined that the tenancy right was acquired in 1954 through payment of a non-refundable security deposit of Rs. 1,080, which represented the cost of acquisition under section 55(2)(a)(i). Since the asset was acquired before April 1, 2001, the appellant was entitled to adopt either the fair market value as on that date or the actual cost as the acquisition cost, with indexation benefits under section 48. Based on the valuation certified by a registered government valuer, the transaction resulted in a net capital loss. The ITAT deleted the addition made by the AO, allowing the appellant's grounds of appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
