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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Objections to reassessment must address material submissions relevant to the alleged source of funds for share purchases. Although the Assessing Officer's reasoning appeared prima facie sustainable on the material initially available, later material comprising a letter and annexures concerning loans and own funds also required consideration before the objections were decided. The order rejecting the objections was therefore set aside, with directions for fresh consideration after examining the additional material. The validity of the reopening was not decided, and all contentions on its merits remained open.
Objections to reassessment must address material submissions relevant to the alleged source of funds for share purchases. Although the Assessing Officer's reasoning appeared prima facie sustainable on the material initially available, later material comprising a letter and annexures concerning loans and own funds also required consideration before the objections were decided. The order rejecting the objections was therefore set aside, with directions for fresh consideration after examining the additional material. The validity of the reopening was not decided, and all contentions on its merits remained open.
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