https://www.taxtmi.com/caselaws?id=450084 ITAT Chennai ruled in favor of the assessee on multiple grounds. The Tribunal upheld CIT(A)'s decision allowing enhanced capital loss claims despite not being filed through revised return, following HC precedent that claims can be considered if relevant material is on record. The reassessment beyond four years was quashed as AO failed to establish assessee's failure to disclose material facts, making it barred under Section 147 proviso. Additionally, the Tribunal confirmed deletion of Rs. 2 crores addition, treating advance/deposits as capital receipt from hotel asset sale rather than business income. Revenue's appeal was dismissed on all counts. en-us Fri, 23 Feb 2024 00:00:00 +0530 Wed, 28 Aug 2024 10:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450084 ITAT Chennai ruled in favor of the assessee on multiple grounds. The Tribunal upheld CIT(A)'s decision allowing enhanced capital loss claims despite not being filed through revised return, following HC precedent that claims can be considered if relevant material is on record. The reassessment beyond four years was quashed as AO failed to establish assessee's failure to disclose material facts, making it barred under Section 147 proviso. Additionally, the Tribunal confirmed deletion of Rs. 2 crores addition, treating advance/deposits as capital receipt from hotel asset sale rather than business income. Revenue's appeal was dismissed on all counts. Case-Laws Income Tax Fri, 23 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450084