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...
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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