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ITAT allowed the assessee's appeal regarding disallowance of loss on Amritsar real estate project. Lower authorities erroneously determined the loss crystallized in AY 2010-11, but ITAT found disputes between parties continued until compromise deed dated 20-7-2012, making AY 2012-13 the correct year for crystallization. The Tribunal noted documentary evidence in Supplementary Paper Book demonstrated ongoing disputes post-2009. ITAT concluded the loss properly crystallized on 20-7-2012 when disputes were finally resolved through compromise deed. The Tribunal emphasized tax rates remained consistent across relevant assessment years, citing precedent that revenue suffers no prejudice when tax rates are uniform, making the timing dispute academic. The assessee's explanation for claiming deduction in AY 2012-13 was accepted as convincing.
ITAT allowed the assessee's appeal regarding disallowance of loss on Amritsar real estate project. Lower authorities erroneously determined the loss crystallized in AY 2010-11, but ITAT found disputes between parties continued until compromise deed dated 20-7-2012, making AY 2012-13 the correct year for crystallization. The Tribunal noted documentary evidence in Supplementary Paper Book demonstrated ongoing disputes post-2009. ITAT concluded the loss properly crystallized on 20-7-2012 when disputes were finally resolved through compromise deed. The Tribunal emphasized tax rates remained consistent across relevant assessment years, citing precedent that revenue suffers no prejudice when tax rates are uniform, making the timing dispute academic. The assessee's explanation for claiming deduction in AY 2012-13 was accepted as convincing.
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