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...
HC held that the assessee's "booking rights" and the resultant capital asset accrued only on execution of the Buyer's Agreement dated 4.11.2004, not on earlier confirmation correspondence; the confirmation letter explicitly disclaimed any grant of provisional/final allotment or title and thus did not create transferable rights. Accordingly, the date of acquisition for capital gains purposes is the date of the Buyer's Agreement, entitling the assessee to indexation calculated from that acquisition date as applicable, and the challenge did not raise any substantial question of law.
HC held that the assessee's "booking rights" and the resultant capital asset accrued only on execution of the Buyer's Agreement dated 4.11.2004, not on earlier confirmation correspondence; the confirmation letter explicitly disclaimed any grant of provisional/final allotment or title and thus did not create transferable rights. Accordingly, the date of acquisition for capital gains purposes is the date of the Buyer's Agreement, entitling the assessee to indexation calculated from that acquisition date as applicable, and the challenge did not raise any substantial question of law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
