https://www.taxtmi.com/caselaws?id=786486 Assessing officer could not substitute declared cost of acquisition of listed shares in a later assessment year by reference to market prices on dematerialisation dates where the purchase and payment were verified and accepted in an earlier scrutiny assessment; each previous year is a distinct unit and tax chargeable to the year in which income arose, so revisiting accepted consideration without cogent adverse evidence is impermissible. The AO also lacked material to treat the differential as income in the year of sale under income attribution principles. Result: substitution and denial of exemption under section 10(38) in the later year was disallowed, favouring the assessee. en-us Tue, 10 Feb 2026 00:00:00 +0530 Fri, 13 Feb 2026 09:18:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786486 Assessing officer could not substitute declared cost of acquisition of listed shares in a later assessment year by reference to market prices on dematerialisation dates where the purchase and payment were verified and accepted in an earlier scrutiny assessment; each previous year is a distinct unit and tax chargeable to the year in which income arose, so revisiting accepted consideration without cogent adverse evidence is impermissible. The AO also lacked material to treat the differential as income in the year of sale under income attribution principles. Result: substitution and denial of exemption under section 10(38) in the later year was disallowed, favouring the assessee. Case-Laws Income Tax Tue, 10 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786486