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...
The ITAT adjudicated a capital gains tax exemption claim under Section 54, reversing lower authorities' decisions. The tribunal held that the assessee was entitled to exemption despite sale proceeds not being directly used for new property acquisition. The court emphasized that Section 54 does not mandate mandatory utilization of sale proceeds, but rather allows appropriation of capital gains towards new residential property investment. The tribunal found the assessee's investment in a new villa exceeded the sale consideration of the old residential house. Consequently, the tribunal set aside the previous order and directed the Assessing Officer to allow the exemption claim, ultimately deciding in favor of the assessee.
The ITAT adjudicated a capital gains tax exemption claim under Section 54, reversing lower authorities' decisions. The tribunal held that the assessee was entitled to exemption despite sale proceeds not being directly used for new property acquisition. The court emphasized that Section 54 does not mandate mandatory utilization of sale proceeds, but rather allows appropriation of capital gains towards new residential property investment. The tribunal found the assessee's investment in a new villa exceeded the sale consideration of the old residential house. Consequently, the tribunal set aside the previous order and directed the Assessing Officer to allow the exemption claim, ultimately deciding in favor of the assessee.
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