Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Section 54F exemption must be given effect before applying the set-off rules for long-term capital loss under section 70(3). The Tribunal held that capital gains chargeability under section 45(1) is itself subject to the exemption provisions, so where section 54F conditions are satisfied, the eligible gain exits the charging computation to that extent first. Only after capital gains are computed under sections 45 to 55A can section 70(3) operate. On the undisputed figures, the assessee was entitled to section 54F relief on the eligible long-term capital gain and also to carry forward the separate long-term capital loss, so the denial of carry forward was unsustainable.
Section 54F exemption must be given effect before applying the set-off rules for long-term capital loss under section 70(3). The Tribunal held that capital gains chargeability under section 45(1) is itself subject to the exemption provisions, so where section 54F conditions are satisfied, the eligible gain exits the charging computation to that extent first. Only after capital gains are computed under sections 45 to 55A can section 70(3) operate. On the undisputed figures, the assessee was entitled to section 54F relief on the eligible long-term capital gain and also to carry forward the separate long-term capital loss, so the denial of carry forward was unsustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
