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 assessee's appeal and deleted additions under sections 50C and 56(2)(x). The Tribunal found the property transfer was inter se relatives (sold to sister-in-law), supported by family chart, ration-card evidence and notarized affidavits, and that the excess of stamp-duty valuation over sale consideration was characterized as gift. Consequently, the differential valuation did not constitute income under section 56(2)(x) and section 50C was inapplicable on the facts. The Tribunal held that both the AO and CIT(A) erred in treating the stamp-duty excess as taxable consideration, and directed deletion of the impugned additions, allowing the appeal.
ITAT allowed the assessee's appeal and deleted additions under sections 50C and 56(2)(x). The Tribunal found the property transfer was inter se relatives (sold to sister-in-law), supported by family chart, ration-card evidence and notarized affidavits, and that the excess of stamp-duty valuation over sale consideration was characterized as gift. Consequently, the differential valuation did not constitute income under section 56(2)(x) and section 50C was inapplicable on the facts. The Tribunal held that both the AO and CIT(A) erred in treating the stamp-duty excess as taxable consideration, and directed deletion of the impugned additions, allowing the appeal.
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