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 of assessment under Section 147 before the 01.04.2021 amendments requires only that the notice under Section 148 be issued within the limitation period; service within that period is not a jurisdictional prerequisite. The date of dispatch governs validity of issuance, so a notice issued on 31.03.2019 remains effective even if actual service occurred later. Applying that rule, the reassessment proceedings were not vitiated by delayed service or an accompanying attachment error, and the writ challenging the reassessment was dismissed.
Reopening of assessment under Section 147 before the 01.04.2021 amendments requires only that the notice under Section 148 be issued within the limitation period; service within that period is not a jurisdictional prerequisite. The date of dispatch governs validity of issuance, so a notice issued on 31.03.2019 remains effective even if actual service occurred later. Applying that rule, the reassessment proceedings were not vitiated by delayed service or an accompanying attachment error, and the writ challenging the reassessment was dismissed.
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