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...
ITAT allowed the taxpayer's appeal, holding that losses from futures and options trading, classified as non-speculative business losses, are admissible for set-off against capital gains and other income under s.71(2). The taxpayer had filed a timely return claiming set-off of F&O business losses against capital gains arising from sale of land and building; the claim was made in the original return. The Tribunal set aside the assessment and remanded the matter to the AO for verification of the particulars furnished by the taxpayer and directed the AO to give effect to the set-off as claimed if verified. Appeal allowed for statistical purposes.
ITAT allowed the taxpayer's appeal, holding that losses from futures and options trading, classified as non-speculative business losses, are admissible for set-off against capital gains and other income under s.71(2). The taxpayer had filed a timely return claiming set-off of F&O business losses against capital gains arising from sale of land and building; the claim was made in the original return. The Tribunal set aside the assessment and remanded the matter to the AO for verification of the particulars furnished by the taxpayer and directed the AO to give effect to the set-off as claimed if verified. Appeal allowed for statistical purposes.
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