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 reversed the disallowance of the set off of short-term capital losses against corresponding gains by the revenue authorities, who had characterized the transactions as accommodation entries without sufficient material. The tribunal found that the lower authorities relied primarily on the quantum of the claim rather than concrete evidence to reject the set off. Consequently, the ITAT held that the assessee was entitled to set off the short-term capital loss against the gains arising from the sale of shares in multiple entities. The disallowance order was quashed, and the assessee's appeal was allowed, permitting the set off and negating any tax liability on the resultant net position.
The ITAT reversed the disallowance of the set off of short-term capital losses against corresponding gains by the revenue authorities, who had characterized the transactions as accommodation entries without sufficient material. The tribunal found that the lower authorities relied primarily on the quantum of the claim rather than concrete evidence to reject the set off. Consequently, the ITAT held that the assessee was entitled to set off the short-term capital loss against the gains arising from the sale of shares in multiple entities. The disallowance order was quashed, and the assessee's appeal was allowed, permitting the set off and negating any tax liability on the resultant net position.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
