Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
ITAT held that deduction under section 54 could not be denied on technical or documentary objections where the record showed substantial investment in construction of a residential house and utilisation of capital gains for that purpose. It accepted the Joint Development Agreement and expenditure evidence as sufficient, noting no specific defect or adverse finding on genuineness, and applied a liberal construction to this beneficial exemption provision. The disallowance was deleted. On Chapter VI-A claims under sections 80C and 80D, the Tribunal upheld the direction to verify the supporting documents and allow the admissible deduction in accordance with law.
ITAT held that deduction under section 54 could not be denied on technical or documentary objections where the record showed substantial investment in construction of a residential house and utilisation of capital gains for that purpose. It accepted the Joint Development Agreement and expenditure evidence as sufficient, noting no specific defect or adverse finding on genuineness, and applied a liberal construction to this beneficial exemption provision. The disallowance was deleted. On Chapter VI-A claims under sections 80C and 80D, the Tribunal upheld the direction to verify the supporting documents and allow the admissible deduction in accordance with law.
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