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...
Deduction for capital gain on agricultural land was upheld where inspectors' post-transfer report and photographs were temporally remote, unnotified, and not authenticated, so they could not rebut revenue records showing the land was used for agriculture as on transfer. The tribunal found the revenue failed to discharge the onus of proving the land's non agricultural character, noted that meagre agricultural income does not change land character, and confirmed the appellate authority's allowance of the deduction under the relevant tax provision.
Deduction for capital gain on agricultural land was upheld where inspectors' post-transfer report and photographs were temporally remote, unnotified, and not authenticated, so they could not rebut revenue records showing the land was used for agriculture as on transfer. The tribunal found the revenue failed to discharge the onus of proving the land's non agricultural character, noted that meagre agricultural income does not change land character, and confirmed the appellate authority's allowance of the deduction under the relevant tax provision.
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