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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Capital gain computation under a joint development agreement was considered with two principal issues: whether deduction for indexed cost of acquisition of land is allowable where land rights were exchanged for constructed area, and whether deduction for cost of construction is allowable though no monetary investment was made by the assessee. The tribunal applied the rule that expenditure wholly and exclusively incurred in connection with transfer and cost of acquisition and improvement must be allowed, concluding the assessee retained compensable rights and was entitled in principle to deductions for indexed acquisition and construction costs; both issues were remitted to the AO for factual verification and quantification with admission of additional evidence.
Capital gain computation under a joint development agreement was considered with two principal issues: whether deduction for indexed cost of acquisition of land is allowable where land rights were exchanged for constructed area, and whether deduction for cost of construction is allowable though no monetary investment was made by the assessee. The tribunal applied the rule that expenditure wholly and exclusively incurred in connection with transfer and cost of acquisition and improvement must be allowed, concluding the assessee retained compensable rights and was entitled in principle to deductions for indexed acquisition and construction costs; both issues were remitted to the AO for factual verification and quantification with admission of additional evidence.
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TaxTMI 
TaxTMI 
of 4918 
