Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Absence of a signature on sanction under the reassessment provisions was treated as a challenge requiring reconsideration after the retrospective insertion of Section 292BC introduced a new legal dimension. Because the assessee had not been given an opportunity in the writ proceedings to address the effect of that retrospective provision, the court restored the writ petition for fresh consideration and left all contentions open. No opinion was expressed on the merits of the reassessment challenge, and the matter was remitted so both sides could address the applicability of the new provision before a final decision.
Absence of a signature on sanction under the reassessment provisions was treated as a challenge requiring reconsideration after the retrospective insertion of Section 292BC introduced a new legal dimension. Because the assessee had not been given an opportunity in the writ proceedings to address the effect of that retrospective provision, the court restored the writ petition for fresh consideration and left all contentions open. No opinion was expressed on the merits of the reassessment challenge, and the matter was remitted so both sides could address the applicability of the new provision before a final decision.
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