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...
ITAT Decision Summary: The ITAT upheld the CIT(A)'s order with modifications, primarily focusing on equitable taxation principles. The tribunal directed the AO to re-compute long-term capital gains by applying the Cost Inflation Index of the year of transfer. The decision rejected revenue's contentions regarding unaccounted transactions, emphasizing that only real income should be taxed. The tribunal confirmed a 30% profit rate for unaccounted business receipts and allowed set-off of expenses against taxed receipts. Key holdings included preventing double taxation, ensuring computational fairness, and adhering to statutory provisions governing capital gains calculation while maintaining the principle of taxing net real income.
ITAT Decision Summary: The ITAT upheld the CIT(A)'s order with modifications, primarily focusing on equitable taxation principles. The tribunal directed the AO to re-compute long-term capital gains by applying the Cost Inflation Index of the year of transfer. The decision rejected revenue's contentions regarding unaccounted transactions, emphasizing that only real income should be taxed. The tribunal confirmed a 30% profit rate for unaccounted business receipts and allowed set-off of expenses against taxed receipts. Key holdings included preventing double taxation, ensuring computational fairness, and adhering to statutory provisions governing capital gains calculation while maintaining the principle of taxing net real income.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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