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 appeal and directed the AO to delete the Rs.27,00,000 addition made to the assessee's income. The Tribunal found the assessee's spouse had disclosed the entire sale consideration in his return, and taxing the same receipt in the assessee's hands would amount to double taxation. Further, the impugned flat was acquired in October 2007 and sold in July 2019, qualifying for long-term capital gains treatment; indexed cost computation yields a capital loss, rendering the AO's short-term capital gains assessment unsustainable. The AO was held to have failed to verify available records, and the addition was quashed.
ITAT allowed the appeal and directed the AO to delete the Rs.27,00,000 addition made to the assessee's income. The Tribunal found the assessee's spouse had disclosed the entire sale consideration in his return, and taxing the same receipt in the assessee's hands would amount to double taxation. Further, the impugned flat was acquired in October 2007 and sold in July 2019, qualifying for long-term capital gains treatment; indexed cost computation yields a capital loss, rendering the AO's short-term capital gains assessment unsustainable. The AO was held to have failed to verify available records, and the addition was quashed.
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