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...
Exemption under section 54 was denied by the Revenue by treating the capital gains as taxable in the relevant year on the premise that the new residential house was not constructed. The appellate authority held that the statute allows a three-year period from transfer for construction, which had not expired in the year under appeal, and the assessee's purchase of land and ongoing construction/investment in the new residential house was undisputed, with completion evidenced subsequently. Accordingly, no addition to capital gains could be made in the year under appeal and the denial of section 54 relief was rejected; the Revenue's appeal was dismissed. - ITAT
Exemption under section 54 was denied by the Revenue by treating the capital gains as taxable in the relevant year on the premise that the new residential house was not constructed. The appellate authority held that the statute allows a three-year period from transfer for construction, which had not expired in the year under appeal, and the assessee's purchase of land and ongoing construction/investment in the new residential house was undisputed, with completion evidenced subsequently. Accordingly, no addition to capital gains could be made in the year under appeal and the denial of section 54 relief was rejected; the Revenue's appeal was dismissed. - ITAT
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