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 upheld the assessee's appeal, rejecting the revisional order under Section 263. The tribunal found no merit in the revenue's allegations regarding inadequate inquiry into long-term capital gains exemption claim. Purchase of shares occurred three years prior to sale, with payments made through banking channels and documented in demat account. The tribunal determined that minor procedural insufficiencies do not warrant revisional proceedings, emphasizing that the Assessing Officer's approach was not perfunctory. Consequently, the revisional order was set aside, affirming the original assessment order and allowing the assessee's exemption claim under Section 10(38).
ITAT upheld the assessee's appeal, rejecting the revisional order under Section 263. The tribunal found no merit in the revenue's allegations regarding inadequate inquiry into long-term capital gains exemption claim. Purchase of shares occurred three years prior to sale, with payments made through banking channels and documented in demat account. The tribunal determined that minor procedural insufficiencies do not warrant revisional proceedings, emphasizing that the Assessing Officer's approach was not perfunctory. Consequently, the revisional order was set aside, affirming the original assessment order and allowing the assessee's exemption claim under Section 10(38).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
