Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
In computing long-term capital gains on transfer of inherited immovable property, the dominant issue was the correct base year and Cost Inflation Index for indexation and FMV as on 01-04-1981. Since the property was admittedly inherited in 1981, indexation had to commence from 01-04-1981 with CII 100, and the Revenue's reliance on CII 172 for FY 1989-90 based on an aborted agreement was held illogical and irrelevant. The AO was directed to recompute LTCG by adopting FMV at ₹17.50 per sq. mtr as on 01-04-1981, using stamp duty valuation as consideration, applying the assessee's proportionate share, and granting eligible relief for investment in a jointly purchased new property. - ITAT
In computing long-term capital gains on transfer of inherited immovable property, the dominant issue was the correct base year and Cost Inflation Index for indexation and FMV as on 01-04-1981. Since the property was admittedly inherited in 1981, indexation had to commence from 01-04-1981 with CII 100, and the Revenue's reliance on CII 172 for FY 1989-90 based on an aborted agreement was held illogical and irrelevant. The AO was directed to recompute LTCG by adopting FMV at ₹17.50 per sq. mtr as on 01-04-1981, using stamp duty valuation as consideration, applying the assessee's proportionate share, and granting eligible relief for investment in a jointly purchased new property. - ITAT
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