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...
ITAT set aside the assessment to the file of the AO and directed recomputation of long-term capital gains (LTCG). The AO must enquire into and allow deduction for cost of acquisition and cost of improvement, if any, after calling for and verifying requisite particulars, because denial without such inquiry was impermissible and the Department must not derive advantage from an assessee's ignorance. The tribunal also directed allowance of deduction under s.54F for construction expenses incurred up to the extended due date under s.139(4), subject to verification that the assessee did not own more than one residential property on the date of sale. The assessee's ground is allowed for statistical purposes.
ITAT set aside the assessment to the file of the AO and directed recomputation of long-term capital gains (LTCG). The AO must enquire into and allow deduction for cost of acquisition and cost of improvement, if any, after calling for and verifying requisite particulars, because denial without such inquiry was impermissible and the Department must not derive advantage from an assessee's ignorance. The tribunal also directed allowance of deduction under s.54F for construction expenses incurred up to the extended due date under s.139(4), subject to verification that the assessee did not own more than one residential property on the date of sale. The assessee's ground is allowed for statistical purposes.
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