Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Tribunal applied Coordinate Bench precedents to permit revised characterisation of investment sale proceeds as capital gains and to allow exemption for long term listed equity gains where the taxpayer chose that treatment; it allowed rent equalisation as a timing difference deduction and upheld allowability of insurance specific provisions including IBNR/IBNER and reinsurance premium deductions. The Tribunal set aside reversal of reserve for unexpired risks to the assessing officer for verification and compliance with Rule 6E conditions, and remitted recomputation and verification of interest to the assessing officer for recalculation in accordance with law.
Tribunal applied Coordinate Bench precedents to permit revised characterisation of investment sale proceeds as capital gains and to allow exemption for long term listed equity gains where the taxpayer chose that treatment; it allowed rent equalisation as a timing difference deduction and upheld allowability of insurance specific provisions including IBNR/IBNER and reinsurance premium deductions. The Tribunal set aside reversal of reserve for unexpired risks to the assessing officer for verification and compliance with Rule 6E conditions, and remitted recomputation and verification of interest to the assessing officer for recalculation in accordance with law.
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