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    <title>2019 (11) TMI 356 - ITAT AHMEDABAD</title>
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    <description>Capital gains on immovable property could not be assessed in the year under consideration because transfer had occurred in an earlier assessment year through the agreement to sell and possession arrangement. After the section 263 revisional order was vacated, the Assessing Officer lacked jurisdiction to reopen that settled issue, rendering the capital-gains addition unsustainable. The difference between job-work income and Form 26AS receipts was explained by netting receipts against purchases; absent adequate enquiry or evidence of undisclosed income, the addition was deleted. As no capital gain arose in the relevant year, the consequential stamp-value addition under section 50C also failed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=388107</link>
      <description>Capital gains on immovable property could not be assessed in the year under consideration because transfer had occurred in an earlier assessment year through the agreement to sell and possession arrangement. After the section 263 revisional order was vacated, the Assessing Officer lacked jurisdiction to reopen that settled issue, rendering the capital-gains addition unsustainable. The difference between job-work income and Form 26AS receipts was explained by netting receipts against purchases; absent adequate enquiry or evidence of undisclosed income, the addition was deleted. As no capital gain arose in the relevant year, the consequential stamp-value addition under section 50C also failed.</description>
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