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 ...
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Section 154 rectification applications must be filed within four years from the end of the financial year in which the order sought to be amended was passed. The notes state that section 154(7) is clear and unambiguous and contains no provision allowing condonation of delay for reasonable cause. On a literal construction, expiry of this period removes the authority's jurisdiction to entertain a rectification application, including applications seeking correction of income returned and processed under section 143(1). Accordingly, the delayed applications were treated as time-barred, their rejection was upheld, and the related appeals were dismissed.
Section 154 rectification applications must be filed within four years from the end of the financial year in which the order sought to be amended was passed. The notes state that section 154(7) is clear and unambiguous and contains no provision allowing condonation of delay for reasonable cause. On a literal construction, expiry of this period removes the authority's jurisdiction to entertain a rectification application, including applications seeking correction of income returned and processed under section 143(1). Accordingly, the delayed applications were treated as time-barred, their rejection was upheld, and the related appeals were dismissed.
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