Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
ITAT ruled on multiple taxation issues: (1) Short-term capital gains (STCG) from rights entitlement are exempt under Article 13(6) of India-Ireland DTAA, rejecting tax authority's denial. (2) Assessee permitted to set off STCG from non-STT paid shares against short-term capital loss (STCL) from STT paid shares, overturning tax officer's restrictive interpretation of section 70. (3) Directed tax authority to consider TDS credit rectification petition and refund claim, ensuring assessee receives procedural fairness and opportunity to be heard.
ITAT ruled on multiple taxation issues: (1) Short-term capital gains (STCG) from rights entitlement are exempt under Article 13(6) of India-Ireland DTAA, rejecting tax authority's denial. (2) Assessee permitted to set off STCG from non-STT paid shares against short-term capital loss (STCL) from STT paid shares, overturning tax officer's restrictive interpretation of section 70. (3) Directed tax authority to consider TDS credit rectification petition and refund claim, ensuring assessee receives procedural fairness and opportunity to be heard.
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