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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The ITAT held that the date of acquisition for computing LTCG on sale of immovable property is the date of the agreement to sale (16 November 2007), not the date of possession (16 December 2010). The tribunal relied on the substantial payments made during FY 2007-08, establishing the appellant's right to hold the asset from the agreement date. Consequently, the AO was directed to compute capital gains for AY 2015-16 using the acquisition date as 16 November 2007, allowing indexation benefits from that year, thereby overturning the assessment order that had considered the possession date.
The ITAT held that the date of acquisition for computing LTCG on sale of immovable property is the date of the agreement to sale (16 November 2007), not the date of possession (16 December 2010). The tribunal relied on the substantial payments made during FY 2007-08, establishing the appellant's right to hold the asset from the agreement date. Consequently, the AO was directed to compute capital gains for AY 2015-16 using the acquisition date as 16 November 2007, allowing indexation benefits from that year, thereby overturning the assessment order that had considered the possession date.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
