Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are establishe...
Admissibility of Documentary Evidence: appellate authority may admit self explanatory documents on first production and uphold deletion of unexplained...
Reopening under section 147 hinged on whether the AO had independent "reasons to believe" or merely adopted borrowed satisfaction from the Insight Portal; the Tribunal found no nexus between materials on record and the information relied upon, holding the AO failed to apply independent mind, so the re-opening was invalid-reassessment order under section 147 quashed. Because the foundational notice was quashed, the Tribunal declined to decide the substantive allegation of bogus long-term capital gains, resulting in a decision for the assessee. - ITAT
Reopening under section 147 hinged on whether the AO had independent "reasons to believe" or merely adopted borrowed satisfaction from the Insight Portal; the Tribunal found no nexus between materials on record and the information relied upon, holding the AO failed to apply independent mind, so the re-opening was invalid-reassessment order under section 147 quashed. Because the foundational notice was quashed, the Tribunal declined to decide the substantive allegation of bogus long-term capital gains, resulting in a decision for the assessee. - ITAT
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