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...
Section 153A's extended ten-year reassessment period is described as being computed differently from the six-year period. The six assessment years immediately precede the assessment year relevant to the search year, whereas the ten-year period runs from the end of that assessment year and includes the search assessment year as its first year. The note states that this interpretation also applies where seized material is received by the jurisdictional Assessing Officer under section 153C. On that computation, the reassessment notice for AY 2015-16 was treated as beyond the permissible period and quashed as time-barred.
Section 153A's extended ten-year reassessment period is described as being computed differently from the six-year period. The six assessment years immediately precede the assessment year relevant to the search year, whereas the ten-year period runs from the end of that assessment year and includes the search assessment year as its first year. The note states that this interpretation also applies where seized material is received by the jurisdictional Assessing Officer under section 153C. On that computation, the reassessment notice for AY 2015-16 was treated as beyond the permissible period and quashed as time-barred.
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