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...
The ITAT set aside the AO's valuation of the land at Rs. 3,621 per sq.yd. and directed adoption of Rs. 15,000 per sq.yd. as the cost of acquisition as of 01.04.2001, granting indexation benefit from that date. The AO's reduction of the covered area to 2,000 sq.ft. was rejected; the Tribunal upheld the covered area at 3,302.51 sq.ft. as per the site plan and draft order. The cost of construction was fixed at Rs. 821 per sq.ft. based on the Registered Valuer's report, rejecting the DVO's lower rate. The AO was directed to recompute Long Term Capital Gain incorporating these findings: land area at 528.125 sq.yd., land cost at Rs. 15,000 per sq.yd., and construction cost at Rs. 821 per sq.ft. The assessee's appeal was allowed accordingly.
The ITAT set aside the AO's valuation of the land at Rs. 3,621 per sq.yd. and directed adoption of Rs. 15,000 per sq.yd. as the cost of acquisition as of 01.04.2001, granting indexation benefit from that date. The AO's reduction of the covered area to 2,000 sq.ft. was rejected; the Tribunal upheld the covered area at 3,302.51 sq.ft. as per the site plan and draft order. The cost of construction was fixed at Rs. 821 per sq.ft. based on the Registered Valuer's report, rejecting the DVO's lower rate. The AO was directed to recompute Long Term Capital Gain incorporating these findings: land area at 528.125 sq.yd., land cost at Rs. 15,000 per sq.yd., and construction cost at Rs. 821 per sq.ft. The assessee's appeal was allowed accordingly.
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