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    <title>2022 (12) TMI 1312 - ITAT VISAKHAPATNAM</title>
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    <description>Reassessment under section 147 was treated as valid where the assessee did not respond to statutory notices and had not filed a return despite a transaction giving rise to taxable capital gains. In a development-agreement transfer, possession under the original agreement fixed taxability in assessment year 2016-17, and a later supplementary deed was treated as an extension rather than a fresh transfer. For capital gains computation, the deemed consideration was linked to the super built-up area and parking area receivable, while NALA charges and property tax were allowed and 46% of deviation charges was attributed to the assessee. Section 54F relief was left to factual verification of residential-house ownership.</description>
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      <description>Reassessment under section 147 was treated as valid where the assessee did not respond to statutory notices and had not filed a return despite a transaction giving rise to taxable capital gains. In a development-agreement transfer, possession under the original agreement fixed taxability in assessment year 2016-17, and a later supplementary deed was treated as an extension rather than a fresh transfer. For capital gains computation, the deemed consideration was linked to the super built-up area and parking area receivable, while NALA charges and property tax were allowed and 46% of deviation charges was attributed to the assessee. Section 54F relief was left to factual verification of residential-house ownership.</description>
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