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...
Assessee's unspent accumulated fund for AY 2009-10 assessed in AY 2015-16: primary issue whether AO rightly invoked s.147 to tax alleged escaped income. Tribunal accepts CIT(A)'s finding that unutilized funds were beyond assessee's control due to injunction and that prior years' excess expenditure could be set off against the accumulated fund following judicial precedent; therefore no income escaped assessment and assumption of jurisdiction under s.147 was unsustainable - consequence: reopening was invalid and the CIT(A)'s grant of relief on merits is upheld, so revenue's grounds are dismissed. - ITAT
Assessee's unspent accumulated fund for AY 2009-10 assessed in AY 2015-16: primary issue whether AO rightly invoked s.147 to tax alleged escaped income. Tribunal accepts CIT(A)'s finding that unutilized funds were beyond assessee's control due to injunction and that prior years' excess expenditure could be set off against the accumulated fund following judicial precedent; therefore no income escaped assessment and assumption of jurisdiction under s.147 was unsustainable - consequence: reopening was invalid and the CIT(A)'s grant of relief on merits is upheld, so revenue's grounds are dismissed. - ITAT
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