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 ...
Section 11 of the Black Money Act required completion of assessment within two years from the end of the financial year in which notice under section 10(1) was issued, so a notice dated 10-04-2018 meant the assessment had to be completed by 31-03-2021 unless a valid exclusion applied. The exchange-of-information exclusion did not apply because the relevant FT & TR references had already been made and the information received before proceedings began. TOLA and Notification No. 113/2021 did not save the delay, as that notification extended time only for the Income-tax Act and the Benami Transactions Act. The assessment order passed on 17-02-2022 was therefore quashed as time-barred.
Section 11 of the Black Money Act required completion of assessment within two years from the end of the financial year in which notice under section 10(1) was issued, so a notice dated 10-04-2018 meant the assessment had to be completed by 31-03-2021 unless a valid exclusion applied. The exchange-of-information exclusion did not apply because the relevant FT & TR references had already been made and the information received before proceedings began. TOLA and Notification No. 113/2021 did not save the delay, as that notification extended time only for the Income-tax Act and the Benami Transactions Act. The assessment order passed on 17-02-2022 was therefore quashed as time-barred.
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