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 held that the transfer of the plot occurred in the previous year relevant to AY 2010-11 (FY 2009-10), since offer, acceptance and consideration were completed in FY 2009-10, payment was made and possession delivered, and the transaction's genuineness was subsequently recorded in a deed. The Tribunal found no contention of unfulfilled conditions and noted the assessee had declared the capital gains in AY 2010-11. Consequently, the disputed capital gains could not be taxed in the later assessment year under consideration. Grounds No. 1 and 2 raised by the assessee were allowed.
ITAT held that the transfer of the plot occurred in the previous year relevant to AY 2010-11 (FY 2009-10), since offer, acceptance and consideration were completed in FY 2009-10, payment was made and possession delivered, and the transaction's genuineness was subsequently recorded in a deed. The Tribunal found no contention of unfulfilled conditions and noted the assessee had declared the capital gains in AY 2010-11. Consequently, the disputed capital gains could not be taxed in the later assessment year under consideration. Grounds No. 1 and 2 raised by the assessee were allowed.
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