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...
Accumulated charitable income validly set aside under the pre-amendment section 11(2) regime remained available for application in the year immediately following the five-year accumulation period. The Finance Act 2022 omission of that additional utilisation year operated prospectively and did not curtail rights attached to accumulations made earlier. Accordingly, application in financial year 2022-23 of income accumulated in financial year 2016-17 was not deemed taxable income for assessment year 2023-24. Return-processing adjustments cannot disallow such a claim where eligibility depends on reconciling records and resolving debatable questions concerning statutory interpretation and the amendment's temporal operation.
Accumulated charitable income validly set aside under the pre-amendment section 11(2) regime remained available for application in the year immediately following the five-year accumulation period. The Finance Act 2022 omission of that additional utilisation year operated prospectively and did not curtail rights attached to accumulations made earlier. Accordingly, application in financial year 2022-23 of income accumulated in financial year 2016-17 was not deemed taxable income for assessment year 2023-24. Return-processing adjustments cannot disallow such a claim where eligibility depends on reconciling records and resolving debatable questions concerning statutory interpretation and the amendment's temporal operation.
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