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 ...
A composite assessment order covering more than one tax period was held unsustainable where the court applied its earlier view that a single show-cause notice or assessment order cannot span multiple tax periods once annual return due dates have been reached. The impugned order, which covered several financial years, was set aside on that defect alone. The petitioner had confined the challenge to this point, so the other objections were left open. Fresh proceedings were permitted year-wise, with the intervening period excluded for limitation purposes.
A composite assessment order covering more than one tax period was held unsustainable where the court applied its earlier view that a single show-cause notice or assessment order cannot span multiple tax periods once annual return due dates have been reached. The impugned order, which covered several financial years, was set aside on that defect alone. The petitioner had confined the challenge to this point, so the other objections were left open. Fresh proceedings were permitted year-wise, with the intervening period excluded for limitation purposes.
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