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 Appellate Tribunal (ITAT) upheld the appellate order granting relief under Section 54F to the assessee trust. The ITAT found the trust to be a private trust for identified beneficiaries (not a charitable AOP), such that trust income is attributable to beneficiaries; the transaction-purchase of land, sale of flat and reinvestment of capital gains into a residential house-would, absent the trust, have been effected in beneficiaries' names and qualified for exemption under Section 54. Consequently, the CIT(A)'s allowance of Section 54F relief was affirmed and the revenue's challenge dismissed.
The Appellate Tribunal (ITAT) upheld the appellate order granting relief under Section 54F to the assessee trust. The ITAT found the trust to be a private trust for identified beneficiaries (not a charitable AOP), such that trust income is attributable to beneficiaries; the transaction-purchase of land, sale of flat and reinvestment of capital gains into a residential house-would, absent the trust, have been effected in beneficiaries' names and qualified for exemption under Section 54. Consequently, the CIT(A)'s allowance of Section 54F relief was affirmed and the revenue's challenge dismissed.
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