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 adjudicated a tax dispute regarding set-off of business losses against short-term capital gains. The tribunal rejected the assessee's contention that prima facie adjustments under section 143(1) cannot be made for debatable issues. While acknowledging no explicit statutory provision clearly permitting set-off of brought forward business losses against short-term capital gains from business asset sales, the tribunal remanded the matter to the Jurisdictional Assessing Officer. The AO was directed to examine the issue comprehensively, considering sections 50 and 71(3), and provide a reasoned determination after affording the assessee an opportunity to present detailed submissions, effectively allowing ground No.4 for statistical purposes.
ITAT adjudicated a tax dispute regarding set-off of business losses against short-term capital gains. The tribunal rejected the assessee's contention that prima facie adjustments under section 143(1) cannot be made for debatable issues. While acknowledging no explicit statutory provision clearly permitting set-off of brought forward business losses against short-term capital gains from business asset sales, the tribunal remanded the matter to the Jurisdictional Assessing Officer. The AO was directed to examine the issue comprehensively, considering sections 50 and 71(3), and provide a reasoned determination after affording the assessee an opportunity to present detailed submissions, effectively allowing ground No.4 for statistical purposes.
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