Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
The ITAT found that the addition relating to alleged immovable property transactions was made without proper verification of the basic facts, particularly because the assessment record showed inconsistency in how the same properties were treated and the AO had shifted between possible taxability under section 56(2)(x) and section 50C. The Tribunal noted that no addition was ultimately made under section 56(2)(x), while the section 50C addition rested on an unverified factual foundation, and the assessee's cancellation claim was unsupported by the record. The matter was therefore restored to the jurisdictional AO for fresh examination and re-adjudication on evidence and enquiry.
The ITAT found that the addition relating to alleged immovable property transactions was made without proper verification of the basic facts, particularly because the assessment record showed inconsistency in how the same properties were treated and the AO had shifted between possible taxability under section 56(2)(x) and section 50C. The Tribunal noted that no addition was ultimately made under section 56(2)(x), while the section 50C addition rested on an unverified factual foundation, and the assessee's cancellation claim was unsupported by the record. The matter was therefore restored to the jurisdictional AO for fresh examination and re-adjudication on evidence and enquiry.
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