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    <title>2026 (4) TMI 1183 - ITAT KOLKATA</title>
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    <description>A notice issued under section 143(2) that was not in the prescribed CBDT format was treated as invalid, and the assessment based on it was quashed. Capital gains on the sale of two Mumbai offices were held to have arisen in the earlier year when agreement, consideration and possession were completed, so taxation again in the impugned year was unsustainable. Claimed cost of improvement for the Visakhapatnam and Jagi Road lands was allowed on the strength of audited records, and the fair market value-based indexed cost claim was accepted. Rental income already offered on accrual basis could not be taxed again on receipt, and the disallowance of club membership and business promotion was deleted for lack of basis.</description>
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      <description>A notice issued under section 143(2) that was not in the prescribed CBDT format was treated as invalid, and the assessment based on it was quashed. Capital gains on the sale of two Mumbai offices were held to have arisen in the earlier year when agreement, consideration and possession were completed, so taxation again in the impugned year was unsustainable. Claimed cost of improvement for the Visakhapatnam and Jagi Road lands was allowed on the strength of audited records, and the fair market value-based indexed cost claim was accepted. Rental income already offered on accrual basis could not be taxed again on receipt, and the disallowance of club membership and business promotion was deleted for lack of basis.</description>
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