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 allowed the appeal: the Revenue's addition under s.50C was rejected and the third proviso's 10% tolerance margin applies retrospectively, disallowing the technical argument that FMV determined by the DVO (versus stamp duty value) justified an uplift; the assessee's challenge on this ground succeeds. Separately, the Tribunal held the assessee entitled to deduction under s.54EC because actual reinvestment and return filing under s.139(1) were established; the claim may be recognized beyond the figures in the original computation as not barred by statute. Net result: impugned s.50C addition set aside and s.54EC relief allowed in favour of the assessee.
ITAT allowed the appeal: the Revenue's addition under s.50C was rejected and the third proviso's 10% tolerance margin applies retrospectively, disallowing the technical argument that FMV determined by the DVO (versus stamp duty value) justified an uplift; the assessee's challenge on this ground succeeds. Separately, the Tribunal held the assessee entitled to deduction under s.54EC because actual reinvestment and return filing under s.139(1) were established; the claim may be recognized beyond the figures in the original computation as not barred by statute. Net result: impugned s.50C addition set aside and s.54EC relief allowed in favour of the assessee.
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