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 ...
Reassessment proceedings initiated by a notice under section 148 treat the return filed in response as a return under section 139. A notice under section 143(2) is required only where the Assessing Officer considers verification necessary or expedient; its absence does not by itself invalidate reassessment, particularly where the taxpayer participated in the proceedings and section 292BB applies. Additions made during reassessment must retain a direct nexus with the recorded reasons for reopening. Where a claimed business loss is set off against unreported non-compete income forming the basis for reopening, examination of that loss is connected to the recorded reasons; the substantive justification remains examinable in statutory appeal.
Reassessment proceedings initiated by a notice under section 148 treat the return filed in response as a return under section 139. A notice under section 143(2) is required only where the Assessing Officer considers verification necessary or expedient; its absence does not by itself invalidate reassessment, particularly where the taxpayer participated in the proceedings and section 292BB applies. Additions made during reassessment must retain a direct nexus with the recorded reasons for reopening. Where a claimed business loss is set off against unreported non-compete income forming the basis for reopening, examination of that loss is connected to the recorded reasons; the substantive justification remains examinable in statutory appeal.
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