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 impugned receipts, received by a housing society from occupying tenants on admission as members, constituted capital contributions/membership fees towards a building repair and development fund and not consideration for transfer within the meaning of s.2(47). The Tribunal found the receipts arose pursuant to membership admission terms and the conveyance/committee records, and that the allottees merely became class members while already in occupation. Consequently, s.50C valuation provisions were inapplicable and the Assessing Officer's addition under s.50C was unsustainable; the addition was deleted and the assessee's appeal allowed.
ITAT held that the impugned receipts, received by a housing society from occupying tenants on admission as members, constituted capital contributions/membership fees towards a building repair and development fund and not consideration for transfer within the meaning of s.2(47). The Tribunal found the receipts arose pursuant to membership admission terms and the conveyance/committee records, and that the allottees merely became class members while already in occupation. Consequently, s.50C valuation provisions were inapplicable and the Assessing Officer's addition under s.50C was unsustainable; the addition was deleted and the assessee's appeal allowed.
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