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...
For capital gains purposes, the Tribunal treated the property as a long-term capital asset because the assessee had paid the full consideration and obtained possession and enjoyment in FY 2013-14; the later formal registration did not control the holding period. On that factual basis, indexation was allowed from FY 2013-14 and the gain was not assessed as short-term capital gain. The Tribunal also accepted registration charges paid in September 2013 as part of the cost of acquisition, since the supporting documents were unchallenged and there was no material to show duplication. The Revenue's appeal was dismissed and the additions were deleted.
For capital gains purposes, the Tribunal treated the property as a long-term capital asset because the assessee had paid the full consideration and obtained possession and enjoyment in FY 2013-14; the later formal registration did not control the holding period. On that factual basis, indexation was allowed from FY 2013-14 and the gain was not assessed as short-term capital gain. The Tribunal also accepted registration charges paid in September 2013 as part of the cost of acquisition, since the supporting documents were unchallenged and there was no material to show duplication. The Revenue's appeal was dismissed and the additions were deleted.
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