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 ...
Carry-forward of business losses requires the loss to be determined from a return filed under section 139(3) and quantified in assessment. Failure to file valid returns for intervening assessment years prevents determination and notification of the unabsorbed loss available for further carry-forward. Consequently, an earlier business loss cannot be set off in later years where intervening returns were not filed. The disallowance of the claimed set-off was upheld, and the appeals were dismissed because no substantial question of law arose.
Carry-forward of business losses requires the loss to be determined from a return filed under section 139(3) and quantified in assessment. Failure to file valid returns for intervening assessment years prevents determination and notification of the unabsorbed loss available for further carry-forward. Consequently, an earlier business loss cannot be set off in later years where intervening returns were not filed. The disallowance of the claimed set-off was upheld, and the appeals were dismissed because no substantial question of law arose.
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