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 notice under section 148 issued on 07.04.2022 for A.Y. 2015-16 was treated as time-barred because the first proviso to section 149(1) preserves the limitation applicable to pre-01.04.2021 assessment years. The six-year period under the unamended regime had expired on 31.03.2022, so the amended law could not revive a notice that was already barred. On that basis, the reassessment order founded on the invalid notice was also quashed, and the remaining grounds were left open.
A notice under section 148 issued on 07.04.2022 for A.Y. 2015-16 was treated as time-barred because the first proviso to section 149(1) preserves the limitation applicable to pre-01.04.2021 assessment years. The six-year period under the unamended regime had expired on 31.03.2022, so the amended law could not revive a notice that was already barred. On that basis, the reassessment order founded on the invalid notice was also quashed, and the remaining grounds were left open.
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