Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT ruled that provisions of section 115BBE(2), which deny set-off of losses against income under section 69, apply prospectively from 01/04/2017 and are not applicable to assessment year 2014-15. The tribunal relied on Vijaya Hospitality and Resorts Ltd. precedent from Kerala HC, which established that amendments to section 115BBE(2) introduced by Finance Act, 2016 take effect from AY 2017-18 onwards. Accordingly, ITAT directed the AO to permit the appellant to set off house property losses against income assessed under section 69, allowing the appellant's grounds of appeal.
ITAT ruled that provisions of section 115BBE(2), which deny set-off of losses against income under section 69, apply prospectively from 01/04/2017 and are not applicable to assessment year 2014-15. The tribunal relied on Vijaya Hospitality and Resorts Ltd. precedent from Kerala HC, which established that amendments to section 115BBE(2) introduced by Finance Act, 2016 take effect from AY 2017-18 onwards. Accordingly, ITAT directed the AO to permit the appellant to set off house property losses against income assessed under section 69, allowing the appellant's grounds of appeal.
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